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Moorebank Precinct West Stage 2

Koala Management Plan

(02) 9868 1933 | PO Box 2474 Carlingford Court NSW 2118 | cumberlandecology.com.au

Final

12 March 2020

SIMTA

http://www.cumberlandecology.com.au/

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Report No. 18194RP1

The preparation of this report has been in accordance with the brief provided by the Client and has relied upon the data and results collected at or under the times and conditions specified in the report. All findings, conclusions or commendations contained within the report are based only on the aforementioned circumstances. The report has been prepared for use by the Client and no responsibility for its use by other parties is accepted by Cumberland Ecology.

Version Date Issued Amended by Details

1 15/10/2019 JL/GK Draft for DPIE review

2 5/12/2019 GK Updates for EES and ER comments

3 GK Final

Approved by: David Robertson

Position: Director

Signed:

Date:

12 March, 2020

12/03/2020

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Table of Contents

Glossary vi 1. Introduction 1

1.1. Background 1 1.2. The Project 2 1.3. Koala Survey History 3 1.4. Project Team 4 1.5. Document Structure 6 1.6. Purpose and Aims 6

2. Statutory Considerations 7 2.1. Environment Protection and Biodiversity Conservation Act 1999 7 2.2. Environmental Planning and Assessment Act 1979 8 2.3. NSW Threatened Species Conservation Act 1995 and Biodiversity Conservation Act 2016 8 2.4. NSW Biodiversity Offsets Policy for Major Projects and the Biodiversity Offsets Scheme 9 2.5. State Environmental Planning Policy No. 44 – Koala Habitat Protection 9 2.6. Koala Recovery Plan 11 2.7. A Review of Koala Tree Use Across New South Wales 13 2.8. Local Planning Instruments and Policies 15

3. Description of the Environment 16 3.1. Location 16 3.2. Topography, Soils and Hydrology 16 3.3. Land Use 16 3.4. Vegetation Communities 17

4. Literature Review 19 4.1. Summary of Resources 19

5. Koala Survey 21 5.1. Specialist Consultation 21 5.2. Field Survey Procedures 21 5.3. Specialist Site Visit 23 5.4. Field Survey Results 24

6. Koala Habitat Requirements and Threatening Processes 29 6.1. Key Habitat Requirements 29 6.2. Threatening Processes 30 6.3. Conclusion 31

7. Distribution of Koala Population and Habitat 32 7.1. Regional Perspective 32 7.2. Koala Habitat and Records 32 7.3. Koala Habitat Ranking 37 7.4. Koala Movement Corridors 38

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8. Mitigation Measures 40 8.1. Purpose 40 8.2. Avoidance 40 8.3. Mitigation Measures 41 8.4. Direct Offsets 48

9. Monitoring and Reporting 50 9.1. Monitoring 50 9.2. Reporting 53 9.3. Implementation Roles and Responsibilities 53 9.4. Review and Improvement 54 9.5. Incidents, non-Compliance and Complaints 54

10. References 55

Table of Tables

Table 1: Listed Koala Food Tree Species for Central Coast KMA (Source: Approved Koala Recovery Plan) ........ 12 Table 2: Detection dog survey effort ................................................................................................................................................ 24 Table 3: PKFTs and other koala use trees recorded within MPW site ................................................................................. 33 Table 4. PKFTs and other koala use trees recorded within the Moorebank Offset Area ............................................. 35 Table 5. PKFTs and other koala use trees recorded within the Bootland ........................................................................... 36 Table 6. Summary of Proposed General Mitigation Measures ............................................................................................... 41 Table 7: Roles and Responsibilities.................................................................................................................................................... 53 Table 8: Independent Planning Commission – Ecological Conditions of Consent ....................................................... A.2 Table 9: Commonwealth – Ecological Conditions of Consent .............................................................................................. A.4 Table 10: KMP Management Actions and Responsibilities .................................................................................................... B.0 Table 11: Responses to Environment, Energy and Science (EES) Group .......................................................................... C.4 Table 12: Response to Environmental Representative comments .................................................................................... C.34

Table of Photographs

Photograph 1: Koala detected in Bootland (Image 1 of 3) ...................................................................................................... 25 Photograph 2: Koala detected in Bootland (Image 2 of 3) ...................................................................................................... 26 Photograph 3: Koala detected in Bootland (Image 3 of 3) ...................................................................................................... 26 Photograph 4: Fence conditions at MPW site near existing Anzac creek culvert (18 Sep 2019) .............................. 27 Photograph 5: Westernmost of 5 culverts at the southern end of the Bootland ........................................................... 46

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Photograph 6. Koala bridge design concept (side view) .......................................................................................................... 46 Photograph 7. Koala bridge design concept (top view) ........................................................................................................... 47 Photograph 8. Examples of Koala-grids .......................................................................................................................................... 48

Table of Appendices

APPENDIX A : Compliance with Conditions of Consent APPENDIX B : KMP Management Actions APPENDIX C : Consultation with Regulators

Table of Figures

Figure 1: Layout of the Moorebank Intermodal Terminal Precinct Figure 2: Location of MPW Stage 2 Development Figure 3: Historic Koala records in the locality Figure 4: Koala Survey Locations Figure 5: Koala Survey Results Figure 6: Location of Intermodal Precinct relative to Campbelltown LGA Figure 7: Vegetation communities of the MPW site and offset areas Figure 8: Koala Movement Corridors Figure 9: Indicative locations of Koala Grids and Koala Bridges

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Glossary

BAM Biodiversity Assessment Method

BAR Biodiversity Assessment Report

BC Act NSW Biodiversity Conservation Act 2016

Bootland The approved Wattle Grove Biobank Area

CEMP Construction Environment Management Plan

CFFMP Construction Flora and Fauna Management Plan

CKPoM Comprehensive Koala Plan of Management

DA Development Application

DoEE Commonwealth Department of Environment and Energy

DPE NSW Department of Planning and Environment

DPIE NSW Department of Planning, Industry and Environment

EES NSW Environment, Energy and Science Group, a division of DPIE

EIS Environmental Impact Statement

EP&A Act NSW Environmental Planning and Assessment Act 1979

EPBC Act Commonwealth Environment Protection and Biodiversity Conservation Act 1999

FBA Framework for Biodiversity Assessment

IPC Independent Planning Commission

KMA Koala Management Area

KMP Koala Management Plan

LEC NSW Land and Environment Court

LGA Local Government Area

MNES Matters of National Environmental Significance

Moorebank site The approved Moorebank Biobank Area

MPE Moorebank Precinct East, parts of the Moorebank Intermodal Terminal as approved under Concept Plan Approval (MP 10_0913) and the MPE Stage 1 Approval (14_6766)

MPW Moorebank Precinct West, parts of the Moorebank Intermodal Terminal as approved under to MPW Concept Plan Approval (SSD_5066) and the MPW EPBC Approval (No. 2011/6086)

OEH Office of Environment and Heritage

OEMP Operational Environment Management Plan

OSD basin On-site detention basin

PKFT Preferred Koala Food Tree

the Review A review of koala tree use across New South Wales (OEH 2018)

SAT Spot Assessment Technique

SEPP 44 State Environment Planning Policy No 44

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SIMTA Sydney Intermodal Terminal Alliance

SSD State Significant Development

the Intermodal Precinct The Moorebank Intermodal Terminal Precinct, comprising Moorebank Precinct West, Moorebank Precinct East, three offset (biobank) sites and a portion of Railcorp land

TSC Act NSW Threatened Species Conservation Act 1995

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Cumberland Ecology has been requested by Sydney Intermodal Terminal Alliance (SIMTA) on behalf of Qube Holdings Pty Ltd (‘the client’) to prepare a Koala Management Plan in relation to the Moorebank Precinct West Stage 2 development (MPW Stage 2).

1.1. Background The MPW Stage 2 development is a State Significant Development (SSD 7709) that forms part of the wider Moorebank Intermodal Terminal Precinct (the Intermodal Precinct). The Intermodal Precinct is broadly comprised of two main development areas: Moorebank Precinct West (MPW) and Moorebank Precinct East (MPE) with three associated conservation or offset sites: the Wattle Grove offset area (also known as the ‘Bootland’), the Moorebank offset area and the Casula offset area and some adjacent land owned by RailCorp (Figure 1). Concept plans and associated modifications have been approved for the MPW and MPE development areas which are progressively being developed in stages.

Development Consent Conditions have been provided by the Independent Planning Commission (IPC) for the proposed development of MPW Stage 2, located within Lots 1, 2, 3 (partial) DP 1197707, and Lots 100 and 101 DP 1049508 (Figure 2). The MPW Stage 2 development is expected to involve the removal of approximately 42.89 ha of native vegetation, which also comprises habitat for various native flora and fauna, including threatened species. Consent Condition B152 requires preparation of a Koala Management Plan (KMP), with cross referenced requirements included in Conditions B2, B155 and B160. Consent Condition B152 states:

“B152. Prior to clearing of native vegetation, a Koala Management Plan (KMP) must be prepared by a suitably qualified person in consultation with the Office of Environment and Heritage (OEH) and be submitted to the Planning Secretary for approval. The KMP must:

(a) make reference to ‘A review of koala tree use across New South Wales (OEH 2018)’;

(b) identify habitat corridors, of adequate dimensions to provide an adequate Koala habitat corridor as supported by a Koala specialist, to provide connectivity both within the Intermodal Precinct area and with other core koala habitat areas (i.e. to the south and to the west along Georges River);

(c) include commitment to retain Koala use trees on site in line with phased earthworks (see e.g. Condition B40);

(d) include details of structures to eliminate barriers to movement (presented by fences, roads, drainage culverts or pits, rail lines and the like) for koalas and other native fauna likely to use the site or habitat corridor;

(e) include details on koala habitat rehabilitation/ restoration within the identified habitat corridors; and

(f) include other measures to minimise the risk of harm to koalas”.

This KMP forms part of the documentation prepared by the client to fulfil the requirements of the consent conditions issued by the IPC. The purpose of this KMP is to provide a management framework for the local

1. Introduction


Koala population and associated habitat known to exist within the MPW Stage 2 development area and relevant offset areas.

1.2. The Project The Intermodal Precinct development generally comprises:

• Construction and 24/7 operation of an intermodal terminal facility to support a container freight throughput volume of 500,000 twenty-foot equivalent units per annum, including:

◌ a rail terminal with nine rail sidings and associated locomotive shifter;

◌ a rail link connection from the sidings to the rail link constructed under MPE Stage 1 (SSD 6766) to the Southern Sydney Freight Line (SSFL);

◌ rail and truck container loading and unloading and container storage areas;

◌ truck waiting area and emergency truck storage area;

◌ container wash-down facilities and degassing area;

◌ mobile locomotive refuelling station;

◌ engineer’s workshop, administration facility and associated car parking; and

◌ operation of the rail link to the SSFL and container freight movements by truck to and from the MPE site.

• Construction and 24/7 operation of a warehousing estate on the northern part of the site servicing the IMT facility and including:

◌ six warehouses with a total gross floor area of 215,000 m2 and, for each warehouse, associated offices, staff amenities, hardstands and truck and light vehicle parking;

◌ 800 m2 freight village (operating from 7am to 6pm, 7 days/ week) including staff/ visitor amenities; and

◌ internal roads, noise wall, landscaping, lighting and signage.

• Intersection upgrades on Moorebank Avenue at:

◌ Anzac Road providing site access; and

◌ Bapaume Road for left turn only out of the site.

• Construction and operation of on-site detention basins, bioretention/ biofiltration systems and trunk stormwater drainage for the entire site.

• Construction works and temporary ancillary facilities, including:


◌ vegetation clearing, topsoil stripping and stockpiling and site earthworks and temporary onsite detention;

◌ importation of up to 1,600,000 m3 of uncompacted fill, temporary stockpiling and placement over the entire site to raise existing ground levels by up to 3 m;

◌ materials screening, crushing and washing facilities;

◌ importation and placement of engineering fill and rail line ballast;

◌ installation and use of a concrete batching plant; and

◌ utilities installation/ connection.

Components of the Intermodal Precinct that form the MPW Stage 2 development area (Figure 2) include:

• Truck processing, holding and loading areas – with entrance and exit from Moorebank Avenue via an upgraded intersection and a round-about to distribute traffic between the warehousing precinct and the wider Intermodal Precinct;

• Rail loading and container storage areas – installation of nine rail sidings, with an adjacent container storage area serviced by manual handling equipment;

• Administration facility – office building with associated car parking and light vehicle access from Moorebank Avenue;

• The Rail link connection – rail sidings within the Intermodal precinct facility, which would be linked (to the south – to the Rail link (constructed as part of the MPE Project (SSD 14- 6766));

• Warehousing area – construction and operation of approximately 215,000 m2 GFA of warehousing, with warehouses ranging in size from 4,000 m2 to 71,000 m2 along with ancillary offices, truck and light vehicle parking and associated warehouse access roads;

• Upgraded intersection on Moorebank Avenue and internal road – including works to Moorebank Avenue, Anzac Road to accommodate the proposed site entrance to Moorebank Avenue, and construction of an internal road; and

• Ancillary works – including vegetation clearing, earth works, drainage and on-site detention, utilities installation/connection, signage and landscaping.

1.3. Koala Survey History In November 2018, Cumberland Ecology was requested on behalf of the client and SIMTA, to provide additional ecological advice in relation to the adequacy of the biodiversity assessment documents submitted to the then Department of Planning and Environment (DPE) for SSD Application No. 16_7709 for Stage 2 of the MPW development (MPW Stage 2 DA) in light of recent unexpected discoveries of koala activity within parts of the Intermodal Precinct.


Although the MPW and MPE development sites and the various stages therein have been assessed as separate SSD applications, the proposed offset sites – the Bootland, the Moorebank offset area and the Casula offset area – collectively service offsetting requirements for the entire Intermodal Project (Figure 1). The Land and Environment Court of NSW (LEC) granted consent for the MPE Stage 1 project on 13 March 2018 subject to Conditions of Consent including, but not limited to, ongoing mitigation and management under a Construction Flora and Fauna Management Plan (CFFMP).

On 6 November 2018, a Koala (Phascolarctos cinereus) was recorded in the northern parts of the Bootland during routine nest box monitoring, being conducted by Arcadis as per the requirements of the CFFMP for the MPE Stage 1 project. The discovery of the Koala within the Bootland was actioned as an ‘unexpected threatened species’ find as per the CFFMP as this species was considered unlikely to occur within the MPE and wider Intermodal Precinct area on the basis of existing ecological assessments.

As the unexpected finds affected the biodiversity assessment outcomes for the MPW Stage 2 DA being assessed by DPE at the time of the unexpected find, koala surveys were conducted by Cumberland Ecology in December 2018 within the MPW Stage 2 area, the Moorebank offset area and the Bootland. The purpose of these surveys was to determine the potential occurrence of koalas within vegetated areas of the Intermodal Precinct and assess if further mitigation and/or compensation strategies, beyond those proposed within the documentation submitted at the time were required in light of the unexpected finds.

No koalas were observed during the surveys conducted by Cumberland Ecology. However, koala faecal pellets (scats) were found at multiple locations within both the Bootland and the south-eastern parts of MPW. A single koala was again detected on an Infra-red (IR) camera within the Bootland in the vicinity of the initial ‘unexpected find’ sighting. Based on the preceding information and survey history, there is no substantive evidence of a resident population existing on-site, the data instead indicating the presence of 1 – 2 transient or recently arrived koalas. Recent koala studies in the Cumberland Plain area indicate that shale-influenced koala habitat can support approximately 0.07 koalas/ha. As such, it is estimated that up to three koalas could be sustained in the Bootland area.

Nonetheless, based on the finding of koala scats within MPW and the Bootland, additional mitigation measures for koalas, including but not limited to, preparation of a KMP were deemed necessary.

1.4. Project Team

1.4.1. Cumberland Ecology This KMP has been prepared by a team of ecologists at Cumberland Ecology, led by Dr. David Robertson as the project director.

Dr. Robertson has over 30 years experience as a specialist ecologist in both botany and zoology. He is also an accredited Biodiversity Assessment Method (BAM) Assessor and was an accredited Biobanking assessor under the former NSW legislation.

David has extensive consultancy experience including direction of numerous ecological assessments for large extractive and infrastructure projects in the Hunter Valley and Central Coast of New South Wales, and the


Bowen and Galilee Basins in Queensland; direction of numerous large, complex and contentious projects in NSW including the ADI site at St Marys in western Sydney and the Clarence Valley Water Supply Project; extensive experience consulting and negotiating outcomes with New South Wales government agencies as well as the Commonwealth; and provision of expert evidence in the New South Wales Land and Environment Court

The primary Cumberland Ecology staff involved in the project have worked extensively within the Western Sydney region and include:

Gitanjali Katrak is a Senior Project Manager/Ecologist at Cumberland Ecology with over ten years of academic and ecological consulting experience. She is an accredited BAM assessor and an accredited AusRivAS assessor for NSW, NT and Qld. She was also an accredited Biobanking assessor under the former NSW legislation.

Gitanjali has conducted numerous flora, fauna and aquatic surveys and has been involved in a diverse array of projects in the extractive, infrastructure, residential and commercial development sectors. This has included several SSD and local development assessments with endangered ecological communities, threatened species and offsetting issues. She has been the lead ecologist for several projects in the wider Western Sydney area including: the Gables Residential development at Box Hill, the former ADI site at St Marys, the Caledonia precinct in Campbelltown and the Riverlands Golf Course development in Milperra.

Jesse Luscombe is a Project Manager/GIS Specialist at Cumberland Ecology who has worked as an ecological consultant since 2017. He has successfully completed the BAM Assessor Accreditation Course and has been involved in several assessments utilising the Biodiversity Assessment Methodology (BAM). He has assisted on several projects in the wider Western Sydney area including: the Gables Residential development at Box Hill, the Riverlands Golf Course development in Milperra and the Greater MacArthur Priority Growth Area.

1.4.2. Koala Specialist Dr. Stephen Phillips is the managing Director/Principal Ecologist of Biolink Ecological Consultants. He has significant expertise in flora and fauna monitoring techniques and survey design, Koala ecology, GIS-based habitat modelling, landscape ecology, vegetation mapping and natural area management. He has extensive Koala ecology experience and was a member of the NSW Koala Recovery Team that guided the preparation of the Koala Recovery Plan. He has authored or co-authored a number of publications relevant to the Koala including publications on issues such as relocation, conservation and feed tree preferences as well as studies on the Koala populations of Campbelltown and Port Stephens LGAs. Dr. Phillips and colleague John Callaghan developed the Spot Assessment Technique (SAT) for monitoring habitat utilisation by Koalas (Phillips and Callaghan, 2011). SAT methodology is widely recognised as best practice for the assessment of habitat use by Koalas and has been further refined with the development of the Rapid SAT survey methodology (Phillips and Wallis, 2016). Dr. Phillips is also an approved koala expert as per the list of approved biodiversity experts published by the Environment Agency Head (delegate) under Section 6.5.2.4 of the Biodiversity Assessment Method. Dr. Phillips has been commissioned by the client to assist in preparation


of the KMP as the “suitably qualified person” required by Consent Condition B152 and has been involved in advisory discussions, a site inspection and reviewing documentation.

1.5. Document Structure This remainder of this report is structured as follows:

• Chapter 2: Description of Statutory Considerations relevant to this KMP;

• Chapter 3: Provides a description of the environment of the intermodal precinct, offset areas and locality;

• Chapter 4: Provides the results of a literature review, including a summary of the documents utilised in the preparation of this management plan;

• Chapter 5: Provides a description of the field survey and assessment methodology and survey results used in this KMP;

• Chapter 6: Provides details of general Koala habitat requirements, conservation status and threatening processes that affect them;

• Chapter 7: Provides details of the Koala habitat and movement in the intermodal precinct and offset areas;

• Chapter 8: Presents details of the mitigation and offset measures that will be implemented as part of the KMP; and

• Chapter 9: Presents details of the monitoring and reporting that will be undertaken as part of the KMP as well as measures for review and improvement of management strategies and roles and responsibilities for implementation of this KMP.

1.6. Purpose and Aims This KMP is a sub-plan to the Construction Flora and Fauna Management Plan and the Operation Flora and Fauna Management Plan and has been developed to address the requirements of MPW Stage 2 consent condition B152 (SSD 7709).

The primary aims of this KMP are:

• To assist in the dispersal into adjoining offset areas of the 1-2 koalas possibly present within approved development areas;

• Undertake clearing activities in approved development areas in a manner that enables passive dispersal of koalas to occur; and

• Facilitate maintenance of connectivity between the Intermodal Precinct and areas of koala habitat to the south of the Intermodal Precinct.


2.1. Environment Protection and Biodiversity Conservation Act 1999 The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) prescribes the Commonwealth’s role in environmental assessment, biodiversity conservation and the management of protected areas of national significance. It also provides a mechanism for national environment protection and biodiversity conservation.

The EPBC Act is administered by the Department of Environment and Energy (DoEE) and provides protection for listed Matters of National Environmental Significance (MNES) including:

• Listed species and communities (e.g. listed threatened species and ecological communities and migratory species);

• Protected areas (e.g. World Heritage properties, Ramsar wetlands of international significance, conservation zones); and

• National, Commonwealth and Indigenous Heritage.

Under the EPBC Act, any action (which includes a development, project or activity) that is considered likely to have a significant impact on MNES must be referred to the Commonwealth Minister for DoEE. The Koala (combined populations of QLD, NSW and ACT) is listed as Vulnerable under the EPBC Act.

The MPW Project was determined to be a controlled action under the EPBC Act (EPBC Reference 2011/6086) and the MPW Concept Environmental Impact Statement (EIS) prepared under NSW legislation was expanded to also address the EPBC Act assessment requirements.

The Ecological Impact Assessment prepared by Parsons Brinckerhoff in 2014 as part of the EIS (Volume 4 – Technical Paper 3) did not record any koalas during field surveys (Parsons Brinckerhoff, 2014). However, koalas were presumed as likely to occur intermittently on site based on habitat assessment and the proposed Biodiversity Offset Strategy included offsets for residual impacts for removal of koala habitat. The MPW Project was granted approval as a controlled action under the EPBC Act in late 2016 (MPW EPBC Approval).

In February 2015, a bilateral agreement was made under Section 45 of the EPBC Act between Commonwealth of Australia and the State of New South Wales relating to environmental assessment. Under the bilateral agreement, the NSW Biodiversity Offsets Policy for Major Projects (OEH, 2014b) and the Framework for Biodiversity Assessment (FBA) (OEH, 2014a) are Accredited Processes. Therefore, any biodiversity offset strategy proposed under the FBA comprises an offset for MNES. Following the records of koalas within the Intermodal Precinct, an EPBC Biodiversity Offset Strategy was prepared by Arcadis in May 2019 (Arcadis, 2019b).

The Commonwealth approval (dated 2016) requires the preparation of environmental management plans, in particular a Construction Environmental Management Plan (CEMP) and an Operational Environmental Management Plan (OEMP), for the protection of the environment, including listed threatened species and communities. This KMP will form a sub-plan within the CEMP and OEMP.

2. Statutory Considerations


Therefore, the KMP prepared in respect of MPW Stage 2 SSD 7709 is considered to be consistent with the conditions of approval under EPBC 2011/6086.

2.2. Environmental Planning and Assessment Act 1979 The EP&A Act is the overarching planning legislation in NSW that provides for the creation of planning instruments that guide land use. The EP&A Act also provides for the protection of the environment, including the protection and conservation of native animals and plants. This includes threatened species, populations and ecological communities, and their habitats of biodiversity values, as listed in the NSW Biodiversity Conservation Act 2016 (BC Act) (replacing the repealed Threatened Species Conservation Act 1995 (TSC Act)) and NSW Fisheries Management Act 1994. The protection of the environment is prescribed in Section 5A of the EP&A Act (significant effect on species, populations or ecological communities or their habitats).

2.2.1. Division 4.1 of Part 4 of the EP&A Act Upon the repeal of Part 3A of the EP&A Act on 1 October 2011, the Environmental Planning and Assessment Amendment (Part 3A Repeal) Act 2011 inserted a new Division 4.1 in Part 4 of the EP&A Act. This Division provides for a new planning assessment and determination regime for SSDs. A SSD is a development declared by a State Environmental Planning Policy or Regional Environmental Planning Policy to be a SSD, or development which the Minister for Planning has called in for determination. The Minister for Planning is the consent authority for SSD.

Secretary’s Environmental Assessment Requirements (SEARs) for the MPW Stage 2 development were provided by the then DPE in July 2016 (ref: SSD 16-7709, dated 14 July 2016). The MPW Stage 2 project has been approved as a SSD.

2.3. NSW Threatened Species Conservation Act 1995 and Biodiversity Conservation Act 2016 The TSC Act was the key piece of legislation in NSW relating to the protection and management of biodiversity and threatened species prior to August 2017. The TSC Act aimed to protect and encourage the recovery of threatened species, populations and communities that are listed under the Act through threat abatement and species recovery programs. The TSC Act required consideration of whether a development (Part 4) or an activity (Part 5) is likely to significantly impact threatened species, populations, communities or their habitat. The potential impacts of any developments, land use changes or activities would need to undergo an “Assessment of Significance” under Section 5A of the EP&A Act.

The TSC Act was repealed on 25 August 2017 and replaced with the BC Act. The purpose of the BC Act is to maintain a healthy, productive and resilient environment for the greatest well-being of the community, now and into the future, consistent with the principles of ecologically sustainable development. The BC Act is supported by a number of regulations, including the Biodiversity Conservation Regulation 2017 (BC Regulation).

The Koala is listed as Vulnerable under the BC Act and was previously listed as Vulnerable under the TSC Act.


2.4. NSW Biodiversity Offsets Policy for Major Projects and the Biodiversity Offsets Scheme The NSW Biodiversity Offsets Policy for Major Projects was released in October 2014 and was applicable to projects that are SSD or State significant infrastructure (SSI) under the EP&A Act. The NSW Biodiversity Offsets Policy for Major Projects requires proponents to apply the Framework for Biodiversity Assessment (FBA) to assess impacts on biodiversity. The FBA also guides the identification of reasonable measures and strategies that can be taken to avoid and minimise impacts on biodiversity associated with a proposal.

The Biodiversity Offsets Policy for Major Projects has recently been replaced by the Biodiversity Offsets Scheme, which was established by the Biodiversity Conservation Regulation 2017 commencing on 25 August 2017. As the SEARs for the SSD 16-7709 were issued prior to 25 August 2017 (ref: SSD 16-7709, dated 14 July 2016), the MPW Stage 2 development comprised a ‘pending or interim application’ under the Biodiversity Conservation (Savings and Transitional) Regulation 2017. Therefore, the MPW Stage 2 development continued to be assessed under the planning provisions of the TSC Act, FBA and Biodiversity Offsets Policy for Major Projects, as required by the SEARs. The MPW Stage 2 project has been approved as a SSD based on assessments conducted using the FBA.

2.5. State Environmental Planning Policy No. 44 – Koala Habitat Protection The aim of State Environment Planning Policy No 44 (SEPP 44) is to “encourage the conservation and proper management of areas of natural vegetation that provide habitat for Koalas, to ensure permanent, free-living populations over their present range and to reverse the current trend of population decline”. The requirement to prepare a KMP is outlined in SEPP 44 and defined in clauses 11(1)(a) and (b).

According to SEPP 44, a KMP is required to accompany development applications (DAs) which affect core koala habitat in Local Government Areas (LGAs) for which a Comprehensive Koala Plan of Management (CKPoM) has not been completed.

As a resident population evidenced by presence of breeding females has not been confirmed within the Intermodal Precinct to date, the site does not strictly fit the definition of ‘Core Koala Habitat’ under SEPP 44. Nonetheless, given the presence of historic records (Figure 3) and recent sightings/evidence of koala occupation, as a conservative measure the site is being treated in a similar manner to core koala habitat and a KMP, in accordance with the conditions of consent issued by the IPC is being prepared, especially as no CKPoM has been completed for the Liverpool LGA, where the Intermodal Precinct is located. As Liverpool LGA is listed in Schedule 1 (Local Government Areas) of SEPP 44, this KMP has been prepared in accordance with the working provisions of the SEPP.

Guidelines for the preparation of a KMP are provided in the SEPP 44 Circular B35 from the-then Director-General of the Department of Urban Affairs and Planning (currently NSW Department of Planning, Industry and Environment (DPIE)). The following matters, as detailed in the guidelines, are required to be considered when undertaking a plan of management:


• An estimate of population size;

• Identification of preferred feed tree species for the locality and the extent of resource available;

• An assessment of the regional distribution of koalas and the extent of alternative habitat available to compensate for that to be affected by the actions;

• Identifications of linkages of core koala habitat to other adjacent areas of habitat and movement of koalas between areas of habitat. Provision of strategies to enhance and manage these corridors;

• Identification of major threatening processes such as disease, clearance of habitat, road kill and dog attack which impact on the population. Provision of methods for reducing these impacts;

• Provision of detailed proposals for amelioration of impacts on koala populations from any anticipated development within zones of core koala habitat;

• Identification of any opportunities to increase size or improve condition of existing core koala habitat, this should include land adjacent to areas of identified core koala habitat;

• The plan should state clearly what it aims to achieve (for example maintaining or expanding the current population size or habitat area);

• The plan should state the criteria against which achievement of these objectives is to be measured (for example, a specified population size in a specific time frame or the abatement of threats to the population); and

• The plan should also have provisions for continuing monitoring, review and reporting. This should include an identification of who will undertake further work and how it will be funded.”

Schedule 2 of SEPP 44 also provides a list of Koala Food Trees. These include:

• Eucalyptus tereticornis (Forest red gum);

• Eucalyptus microcorys (Tallowwood);

• Eucalyptus punctata (Grey Gum);

• Eucalyptus viminalis (Ribbon or manna gum);

• Eucalyptus camaldulensis (River red gum);

• Eucalyptus haemastoma (Broad leaved scribbly gum);

• Eucalyptus signata (Scribbly gum);

• Eucalyptus albens (White box);

• Eucalyptus populnea (Bimble box or poplar box); and

• Eucalyptus robusta (Swamp mahogany).


2.5.1. State Environmental Planning Policy (Koala Habitat Protection) 2019 SEPP 44 is to be replaced by State Environmental Planning Policy (Koala Habitat Protection) 2019 on 1 March 2020 (Koala Habitat Protection SEPP). Although the Koala Habitat Protection SEPP is not legally in force at the time of preparation of this KMP, consideration has nonetheless been given to fact that the Koala Habitat Protection SEPP significantly expands the SEPP 44 list of koala trees from 10 to 123. These 123 species are categorised into nine distinct regions (Koala Management Areas), according to what trees koalas have been reported to use to varying degrees in various areas, ranging from nine in the Riverina region to 65 in the Central Coast region.

2.6. Koala Recovery Plan In December 2008, a Koala Recovery Plan was approved by the NSW Government (DECC, 2008) within which Liverpool LGA was not identified as a priority area for the development of a CKPoM. Nonetheless, the objectives of the Koala Recovery Plan include the following:

• The integration of koala habitat conservation into local and state government planning processes;

• Development of appropriate road risk management in areas of koala habitat;

• Implementation of strategies which minimise the impacts of domestic dogs on free ranging koalas;

• Development and implementation of strategies to reduce the impact of fires on koala populations; and

• The rehabilitation and restoration of koala habitat and populations.

The Koala Recovery Plan identifies seven koala management areas (KMAs) across NSW based on landscape characteristics, particularly the geographic distribution of primary or secondary food tree species, and administrative boundaries for ease of natural resource management (see Image 1). The koala food trees differ between the seven management areas.

The Intermodal Precinct and broader Sydney Metropolitan Area lie within the Central Coast KMA (KMA 2) The main koala food trees in this KMA, as per the Recovery Plan are listed in Table 1 below.


Image 1: KMAs as per Koala Recovery Plan

Table 1: Listed Koala Food Tree Species for Central Coast KMA (Source: Approved Koala Recovery Plan)

Primary food tree species Secondary food tree species Supplementary Species

Eucalyptus amplifolia Eucalyptus baueriana Eucalyptus agglomerata

Eucalyptus microcorys Eucalyptus bosistoana Eucalyptus bensonii

Eucalyptus parramattensis Eucalyptus camphora Eucalyptus blaxlandii

Eucalyptus robusta Eucalyptus conica Eucalyptus camfieldii

Eucalyptus tereticornis Eucalyptus consideniana Eucalyptus cannonii

Eucalyptus viminalis Eucalyptus cypellocarpa Eucalyptus capitellata

Eucalyptus dwyeri Eucalyptus eugenioides

Eucalyptus glaucina Eucalyptus globoidea

Eucalyptus goniocalyx Eucalyptus imitans

Eucalyptus largeana Eucalyptus ligustrina

Eucalyptus longifolia Eucalyptus muelleriana

Eucalyptus maidenii Eucalyptus oblonga

Eucalyptus michaeliana Eucalyptus prominula

Eucalyptus microcarpa Eucalyptus ralla

Eucalyptus moluccana Eucalyptus sparsifolia


Primary food tree species Secondary food tree species Supplementary Species

Eucalyptus notabilis Eucalyptus tenella

Eucalyptus ovata

Eucalyptus praecox

Eucalyptus punctata

Eucalyptus quadrangulata

Eucalyptus resinifera

Eucalyptus rudderi

Eucalyptus scias

Some tree species listed in the Koala Recovery plan are specifically listed as Koala Food Trees in Schedule 2 of SEPP44. These koala food trees are indicated in bold in Table 1. Additional species listed as Koala food trees (NSW Planning & Environment 2016) in Appendix 2 of “A review of koala tree use across New South Wales (OEH 2018)” (see Section 2.7) are underlined in Table 1.

Further details on preferred feed tree species for the locality and the extent of resource available are provided in Section 5.2.1 and Section 7.2 of this KMP.

2.7. A Review of Koala Tree Use Across New South Wales The NSW Government has embarked upon a program of state-wide koala habitat suitability mapping in response to recommendations put forward by the NSW Chief Scientist & Engineer in addressing the decline of koala populations in key areas of New South Wales. The mapping is intended to complement koala habitat information at local scales as well as information at the state and regional scale about likely koala occurrence or occupancy.

As part of the development of a state-wide habitat suitability map, the Office of Environment and Heritage (OEH, now Environment, Energy and Science Group (EES)) implemented a review of koala tree use and published the document “A review of Koala tree use across New South Wales” (OEH, 2018) (the ‘Review’).

The Review concluded that while koalas generally make use of a variety of tree species, whether for food, shelter or other purposes, within any location they typically display a dietary preference for a subset of tree species that may be considered of primary importance, with others used either for secondary browsing or as resting and shelter sites. The subset of preferred food trees varies across New South Wales.

As part of the Review, NSW was regionalised into seven Koala Management Areas (KMAs) that were used to collate Koala tree use evidence. KMAs were originally formalised within the NSW Koala Recovery Plan (DECC, 2008) and koala food tree lists were developed for each KMA (see Table 1 in Section 2.6). Based mostly on qualitative information, the Review identified evidence of koala use for 137 tree species across New South Wales.


Koala tree use (comprising food, shelter or other purposes) within the KMAs was standardised into four categorical use levels: high, significant, irregular and low. Appendix 2 of the Review provided an updated status on trees considered to comprise food trees across NSW.

The Intermodal Precinct and broader Sydney Metropolitan Area lie within the Central Coast KMA (KMA 2) as indicated in the extract from the document in Image 2 below.

Image 2: Extent of Central Coast KMA as per the OEH Koala tree use review document

Amongst other things, the qualitative evidence gathered by the Review implied that koalas made use a greater diversity of eucalypt species (55 documented) in KMA 2 than any other. These numbers reflect the presence of considerable ecological variation in plant community types and koala habitat diversity within KMA 2 from the coastal lowlands to the Blue Mountains hinterland and the Southern Highlands. Two species, Eucalyptus punctata (Grey Gum) and Eucalyptus globoidea (White Stringybark) were identified as regional high use species by the Review.


The Review hypothesised that the concept of preferred tree species may be less well-defined within KMA 2 and in this context considered that it may be the case that, above a minimum habitat quality threshold, that koalas in these locations persist by occupying relatively large home ranges supporting a diverse range of tree species and topography and the opportunity to access a variety of leaf nutrient and moisture levels while off-setting leaf toxin loads to meet nutritional needs along with shelter and social needs.

Although koala tree use, as defined in the Review, has been considered for this KMP, on the advice of Dr. Phillips the assessment of koala habitat has largely been based on the presence of a subset of dietary preference trees or Preferred Koala Food Trees (PKFTs) for the region as it is the presence of PKFTs that largely determine the carrying capacity of a specific area to support Koalas. The PKFTs utilised within this KMP are largely based on known food trees as defined in the Koala Recovery Plan, studies of the Campbelltown Koala Population (see Section 7.1) and advice from Dr. Phillips with consideration to the updated list of food trees listed in Appendix 2 of the Review.

2.8. Local Planning Instruments and Policies The Liverpool Local Environment Plan 2008 makes little mention of Koalas or their habitat within the LGA. The LEP states under Part 3.2 (3A) that “to be complying development, the development must also be consistent with any plan of management approved under State Environment Planning Policy No 44 – Koala Habitat Protection that applies to the land.” This KMP has been made consistent with the requirements of SEPP 44.

Parts of the Intermodal Precinct, primarily the Bootland, the Moorebank offset site and parts of the MPW development area are mapped as Regional Core and Regional Connected Vegetation in the Liverpool Biodiversity Management Plan 2012. Although Koalas are not specifically mentioned, the objectives of the Regional Core and Regional Connected Vegetation are to protect remaining high conservation value vegetation and linkages. The Intermodal Precinct development is largely consistent with these objectives as the best quality areas of vegetation are to be conserved as Biobank sites.


3.1. Location The project boundary is located approximately 3 km south west of the local township of Moorebank and approximately 27 km from the Sydney Central Business District. The project boundary falls entirely within the Liverpool LGA and is bounded to the west by the Georges River, south by the East Hills Railway, east by the local township of Wattle Grove and north by the M5 Motorway. The Holsworthy Military Barracks are located immediately to the south of the East Hills Railway. At present, the land within the Intermodal Precinct is zoned under the Liverpool LEP as follows:

• MPW and MPE development area: IN1 – General Industrial;

• Moorebank and Casula Offset Areas: E3 – Environmental Management; and

• Wattle Grove Offset Area/Bootland: SP2 – Infrastructure (Defence).

3.2. Topography, Soils and Hydrology The project boundary is located on the south eastern reaches of the Cumberland Plain with the topography generally flat and sloping towards the Georges River. Flat, open grasslands, scattered patches of vegetation and cleared areas dominate the MPW and MPE development areas while the Bootland and Moorebank Offset Area contain relatively dense bushland.

The Intermodal Precinct is located within the Georges River Alluvial Plain Mitchell landscape which generally consists of Quaternary and Tertiary alluvial sediments. Soils mostly consist of clayey sand and sand with limited gravel with a general elevation of 0 to 30m.

The Georges River flows north along the western edge of the MPW site where it is considered to be a 6th order stream. Anzac Creek originates from the MPW Site and is therefore considered to be a 1st order stream within the Intermodal Precinct. The creek flows north past the adjoining suburbs of Wattle Grove and Moorebank before draining into Lake Moore in Chipping Norton, which flows into the Georges River.

In addition to these named watercourses, there is a formalised drainage channel located in the north of the MPW site. The large open channel is concrete lined and conveys stormwater in a north-westerly direction across the MPW site, discharging into the Georges River. Other hydrological features are restricted to artificial wetlands that have naturally regenerated in previously excavated areas with retained soil material and detention basins in the MPW Site.

3.3. Land Use The land within the Intermodal Precinct, particularly the MPW and MPE development areas, and general locality has been extensively modified by historic clearing and ongoing development.

The Intermodal Precinct has been associated with the military since the early 1900s, including use as a training camp, barracks or military storage facilities. Prior to development for the Intermodal Precinct, the MPE site largely comprised developed handstand areas including warehouses, offices and an internal road network. The MPW site largely contained military barracks including the Moorebank Barracks and Steele Barracks as well as the Royal Australian Engineers (RAE) Golf Club. While vegetation in the Bootland was

3. Description of the Environment


largely retained, this area was historically utilised for military training (including as a grenade range) and stockpiling and has required remediation for unexploded ordinance.

The Intermodal Precinct is located near a number of significant industrial areas, including Moorebank and Warwick Farm to the north, Chipping Norton to the north-east, Prestons to the west and Glenfield and Ingleburn to the south-west. Nearby residential areas include Wattle Grove, Moorebank, Holsworthy and Casula, which are located to the east and north east.

3.4. Vegetation Communities Much of the vegetation of the Intermodal Precinct and broader locality has been extensively modified due to a history of clearance, and utilisation for residential, infrastructure, military and industry. This has arguably reduced the availability of habitat for the Koala in the locality with the majority of records occurring within the forested areas of Holsworthy Military Barracks and riparian corridors (Figure 3).

A suite of native woodland and forest communities have been identified as occurring within the Intermodal Precinct. Further details on these communities as they relate to the Intermodal Precinct and Koala habitats are provided in Chapter 7.

According to the Biodiversity Assessment Report (BAR) update conducted by Arcadis in March 2019 (‘the BAR’) (Arcadis, 2019a) the majority of the vegetation within MPW Stage 2 consists of remnant forest and woodland vegetation that has been moderately modified. There are however, some areas of moderate to good condition remnant vegetation that is connected to the larger areas of vegetation in the Moorebank Offset area.

The most extensive and highest quality native vegetation remnants within and adjacent to MPW Stage 2 occur in the Bootland and Moorebank offset areas. Both these areas have specifically been excluded from the Disturbance Area for the project and will be managed in accordance with the BioBanking assessment prepared for the sites (WSP Parsons Brinckerhoff, 2017).

The native flora assemblage of the project boundary is typical of the Cumberland Plain grassy woodlands and open forests. It is characterised by a high diversity of ground cover forbs and grasses and contains a sparse to locally dense shrub stratum that includes Acacia, Melaleuca and Banksia species. In areas of MPW that have experienced more intense infrastructure use, the understorey component is dominated by hardy native grasses (e.g. Microlaena stipoides) or is dominated by weedy grasses and forbs in more modified areas.

Native vegetation communities within MPW Stage 2 development area are in a moderate condition, albeit fragmented, and are largely restricted areas adjacent to the Georges River riparian corridor and the former RAE Golf Club. Remnant woodland patches contain healthy, mature trees and generally support a healthy and diverse understorey.

Parts of the MPW Stage 2 development contain planted vegetation within mown grassy verges. Planted trees comprise a mix of local endemics and non-endemic native eucalypts such as Eucalyptus microcorys, Eucalyptus saligna x botryoides and Eucalyptus camaldulensis.


The vegetation within the offset areas are also generally typical of undisturbed examples of these vegetation communities. Specifically, according to the BAR, vegetation in these areas consists of remnant and regrowth vegetation that has been subjected to minor weed invasion in small areas. Vegetation within the Bootland is generally in a better condition than the Moorebank and Casula offset areas which are subject to higher levels of weed invasion.


Desktop assessments were undertaken as an initial part of the preparation of this KMP. Mapping and Koala records for the surrounding locality were assessed in addition to a review of strategic planning documents, reports and literature relevant to the Koala and the Intermodal Precinct. Relevant available information on the occurrence and habitats of Koalas within the Intermodal Precinct and general locality were considered during the preparation of this document.

Specific information relied upon for Koala records for the surrounding locality included records held within the OEH Atlas of NSW Wildlife Database and maps from the Recovery Plan for the Koala (DECC, 2008). Additionally, information related to the presence of koala trees, in particular known PKFTs for the KMA, was obtained from the recent surveys undertaken as part of the BAR (Arcadis, 2019a) and the Biobanking assessment (WSP Parsons Brinckerhoff, 2017).

Information on the extent of tree species with the potential to be koala use trees, including known PKFTs within the locality was drawn from the desktop review and field surveys and vegetation community mapping of the MPW and MPE development areas and offset areas undertaken by Arcadis (Arcadis, 2019a) and the OEH mapping of native vegetation for the Sydney Metropolitan area (OEH, 2016).

4.1. Summary of Resources Numerous resources were used during the preparation of this KMP in order to adhere to the requirements set by the conditions of consent for the MPW Stage 2 development. Resources included advice from ongoing communications with Dr. Phillips, peer-reviewed documents relating to Koala conservation and management for the Sydney region and site-specific documentation prepared in relation to the development of the Intermodal Precinct. The documents reviewed include, but are not limited to:

• Arcadis (2017). Sydney Intermodal Terminal Alliance (SIMTA): Moorebank Precinct East Stage 1 Biodiversity Assessment Report;

• Arcadis (2019a). Moorebank Precinct West (MPW) – Stage 2 Amended Proposal: Biodiversity Assessment Report;

• Arcadis (2019b). Moorebank Precinct West (SSD – 5066): EPBC Biodiversity Offset Strategy;

• Biolink (2016). Analysing the historical record: aspects of the distribution and abundance of koalas in the Campbelltown City Council Local Government Area 1900 – 2012 (Including an Appendix on Habitat Use and Classification): Report to Campbelltown City Council. Biolink Ecological Consultants, Uki, NSW;

• Biolink (2018). Review of koala Generational Persistence across Campbelltown City Council Local Government Area: 2012 - 2017. Biolink Ecological Consultants, Uki, NSW;

• DECC (2008) Recovery Plan for the koala (Phascolarctos cinereus): Approved Recovery Plan.

• Liverpool City Council (2012). Liverpool Biodiversity Management Plan;

• OEH (2016) The Native Vegetation of the Sydney Metropolitan Area: Version 3.0;

• OEH (2018) A review of Koala tree use across New South Wales;

4. Literature Review


• OEH (2019a). BioNet Atlas records for Koala (Phascolarctos cinereus);

• OEH (2019c). Moorebank Intermodal Terminal Biobank Site: Biobanking Agreement (ID number BA341);

• Parsons Brinckerhoff (2014). Moorebank Intermodal Terminal – Ecological Impact Assessment. Moorebank Intermodal Terminal Project Environmental Impact Statement Volume 4 – Technical Paper 3 Ecological Impact Assessment (with associated Biodiversity Offset Strategy).

• Phillips, S. and Callaghan, J. (2000). Tree species preferences of koalas (Phascolarctos cinereus) in the Campbelltown area south-west of Sydney, New South Wales. Wildlife Research 27: 509-516.

• SIMTA (2018). Moorebank Precinct East Stage 1, Package 2: Construction Flora and Fauna Management Plan;

• Sluiter, A.F. Close, R.L. and Ward, S.J. (2002). Koala feeding and roosting trees in the Campbelltown area of New South Wales. Australian Mammalogy 23: 173-175.

• State Environmental Planning Policy No 44 – Koala Habitat Protection;

• WSP Parsons Brinckerhoff (2017). Moorebank Intermodal Company Biodiversity Assessment Report: Biobanking Agreement Wattle Grove Offset Area, Casula Offset Area and Moorebank Offset Area.


This chapter details the methodology used to investigate the extent of habitat use by koalas within MPW and associated offset areas. Methods undertaken included field surveys and survey data analysis. Specialist consultation was undertaken for the development of survey methods and this KMP.

5.1. Specialist Consultation Prior to undertaking field surveys in November-December 2018, Dr. Phillips was consulted regarding the development of a suitable methodology to determine the extent of use of habitat within MPW and the associated offset areas. Cumberland Ecology continued to liaise with Dr. Phillips throughout the development of the KMP to further refine requisite management strategies based on findings of survey data and non-ecological constraints associated with the development. All data analyses were undertaken by Cumberland Ecology, with advice sought as required from Dr. Phillips. This KMP document was also reviewed by Dr. Phillips.

5.2. Field Survey Procedures

5.2.1. Rapid Spot Assessment Technique surveys Koala surveys were undertaken on 30 November 2018 using a variant of the standard Spot Assessment Technique (SAT) methodology, otherwise known as Rapid–SAT. Rapid-SAT surveys are utilised as a precursor to detailed SAT surveys as this offers a time and very cost effective survey technique based on the knowledge that in areas being utilised by koalas, there is a 50% probability of faecal pellets occurring within 1 m of the base of any PKFT ≥ 300 mm diameter at breast height (DBH) (Phillips and Wallis, 2016). If evidence of Koalas is detected, Rapid-SATs can then be followed by full SATs until the entire area of koala activity is captured.

A 250 m sampling grid was established over the project boundary and offset sites, with a total of 31 Rapid-SAT survey sites established across the areas. As Rapid-SATs allow for some flexibility in site placement (± 25m) to optimise numbers of PKFTs being sampled, sites were adjusted as required in the field.

Based on vegetation mapping and trees (including planted natives) recorded within MPW and associated offset sites, as detailed in the ecological documentation for the MPW and MPE sites, the PKFTs (as listed in SEPP 44, KMA 2 of the Recovery Plan or as advised by Dr. Phillips) within this area comprise:

• Eucalyptus tereticornis (Forest Red Gum), Eucalyptus parramattensis (Parramatta Red Gum), Eucalyptus microcorys (Tallowwood), Eucalyptus robusta (Swamp Mahogany) Eucalyptus moluccana (Grey Box), Eucalyptus longifolia (Woollybutt) and Eucalyptus baueriana (Blue Box).

An additional species, Eucalyptus punctata (Grey Gum) is also considered to be a PKFT for the area but has not been recorded within the Intermodal Precinct in any ecological assessments conducted to date.

At each Rapid-SAT survey site, a maximum of two-person minutes was spent searching for faecal pellets (scats) within a one metre radius of the base of each selected tree and continued until a minimum of five to a maximum of seven PKFTs were searched. Searching for scats involved an initial inspection of the ground surface followed by a robust disturbance, i.e. raking of the leaf litter if necessary, to search for scats. Searching ceased if a Koala scat was located before the two minutes expired.

5. Koala Survey


The locations of Rapid-SAT searches are provided in Figure 4.

5.2.2. IR Cameras A total of seven IR cameras were set up on 30 November 2018 in areas with high numbers of PKFTs or in areas deemed to be potential movement corridors for koalas. The IR cameras were placed in suitable trees facing PKFTs, at a height of approximately two metres and were programmed to take a set of three continuous photos when the motion trigger was activated. The locations of IR cameras within the MPW site and offset areas are shown in Figure 4

The IR cameras were collected on 19 December 2018 and all photographs taken were examined by an ecologist between 8 and 10 January 2019 for presence/absence of fauna.

5.2.3. Koala Detection Dog Surveys using a koala detection dog were conducted from 3 – 7 December 2018 with ecologists from Cumberland Ecology accompanying the ReconEco handler/dog team.

The nominated detection dog, Jet, is a working Springer Spaniel certified for Koala pellet detection with the Canine Detection Certification Council - Conservation Division (CDCC). The nominated handler, Craig Faulkner, is a professionally trained detection dog handler, certified by the CDCC.

The handler allowed the dog to work off leash and follow any scents as far as practical and safe. The surveys involved the handler giving the dog the general direction of the search and guiding/recalling the dog if it strayed too far or to keep the dog safe from risks. The detection dog was fitted with a real-time radio-tracking collar paired with the handler's handheld GPS unit to maintain a record of the areas surveyed and distance covered by the detector dog.

When the dog displayed particular interest in an area, by sitting beside a tree after following a scent, the handler recalled the dog and then rereleased him for a follow-up search. If the dog returned to the point of interest, the handler notified the accompanying Cumberland Ecology ecologists who then conducted searches for scats at the base of the tree of interest as well as any adjacent trees.

The location of any detected scats was recorded using hand-held GPS units and samples were collected for further laboratory confirmation analyses. In areas where high numbers of scats were recorded, PKFTs and adjacent sheltering trees were inspected for koalas.

The areas covered during the detection dog surveys are indicated in Figure 4.

5.2.4. Koala Scat Identification A subset of scat samples located during the dog detection surveys, particularly those within the MPW site, were collected and sent to Ms Georgeanna Story at ScatsAbout for further identity verification.

5.2.5. Survey Limitations Due to time limitations during the survey period, only 16 Rapid-SAT survey points were assessed on 30 November 2018. However, the sites that were not assessed using Rapid-SATs were either located in the


vicinity of the area where a koala was first detected or were subsequently surveyed during the detection dog surveys. As the purpose of Rapid-SATs is to detect evidence of koalas within an area, further Rapid-SAT surveys were deemed unnecessary in these areas.

Due to a device fault on the day, the distance covered by the detection dog was not properly recorded on 4 December 2018. Therefore, the shorter distance covered by the dog handler has been utilised for survey effort calculations for this day.

Due to time limitations during the survey period, scats found within the Bootland on 7 December 2018 were not included in the samples sent to ScatsAbout for laboratory analysis. Samples sent for identification were limited to the scats collected during the Rapid-SAT surveys on 30 November 2018 and during the detection dog surveys within the MPW site on 5 December 2018. Nonetheless, all scats detected during the 7 December surveys are considered to comprise koala scats as they were found by a detection dog that is attuned to koala detection and is not trained for detection of alternate native fauna with similar scats.

5.3. Specialist Site Visit A site inspection to better inform the preparation of this KMP was conducted on 18 September 2019. The site inspection was conducted by Dr. Phillips and Cumberland Ecology ecologists Gitanjali Katrak and Jesse Luscombe. Dr. Phillips, Dr. Katrak and Mr. Luscombe were accompanied by Qube representative Mr. Mark Griffith, Environmental advisor Mr. Richard Johnson (Aspect Environmental), project manager Ms. Tracy Davey (Tactical Group) and site manager Mr. Ian Irwin (Tactical group).

The site inspection involved inspections of vegetation in parts of the MPW site, Moorebank offset area and the Bootland to determine suitability of vegetation as koala habitat and potential movement corridors identified during desktop assessments as well as determine measures required to prevent future koala access to areas approved for development.

In particular, the areas inspected included:

• Vegetation along the boundary of the MPW site and Moorebank offset areas in the vicinity of proposed onsite detention (OSD) basins;

• Vegetation along the eastern boundary of the MPW site in the vicinity of the existing Anzac Creek culvert under Moorebank Avenue;

• Access conditions in the southern parts of the MPW site near the newly constructed MPE Stage 1 rail link; and

• Vegetation along the southern boundary of the Bootland adjacent to the East Hills Railway corridor, in particular a section with existing culverts under the rail-line identified in desktop assessments.


5.4. Field Survey Results

5.4.1. Rapid-SAT surveys Rapid-SAT surveys were conducted at 16 sites. Koala scats were detected at one survey site within the Bootland with additional scats incidentally located under a Eucalyptus fibrosa tree. The locations where the scats were found is shown in Figure 5. These scats located were identified as 'probable' Koala scats by Ms. Story as they did not display all the diagnostic characteristics.

No scats were recorded within the MPW development area or Moorebank offset area during the Rapid-SAT surveys and no koalas were sighted during the Rapid SAT surveys.

5.4.2. Detection Dog surveys Koala scats were found at the base of several trees across two 'patches' of vegetation during the detection dog surveys. The location of these scats is shown in Figure 5.

One detection 'patch' was located in the southern parts of the Bootland while one patch was located in the south-eastern parts of the MPW site. The vegetation communities where the scats were located are discussed further in Section 7.2.3.

The distance covered by the detection dog varied each day. The survey effort, expressed as a ratio of the number of locations of scat detection to distance surveyed, is summarised in Table 2 below.

Table 2: Detection dog survey effort

Survey date Location Distance covered by detection dog (km)

Number of locations of detected scats

Detection/unit effort (# scats/km)

03-12-18 MPW development site 16.24 0 0.00

04-12-18 MPW development site 11.74* 0 0.00

05-12-18 MPW development site 18.98 5 0.26

06-12-18 Moorebank offset area 19.8 0 0.00

07-12-18 Bootland 14.62 13 0.89 * Distance covered by the dog handler used as a proxy due to a device fault on the day. Distance covered by the detector dog would be higher.

Overall the detection rate for koala scats within the Bootland was approximately 3 times that within the MPW site. This suggests a higher density of koala scats and therefore higher level of koala usage of vegetation within the Bootland compared to the MPW site.

5.4.3. IR Camera A single koala was detected on an IR camera (IR 24) located within the Bootland on 9 December 2018. The photograph quality does not allow for definitive gender identification.


The relevant IR camera is located between areas where koala scats were detected during the November-December 2018 surveys (Figure 5). The images captured by the IR camera are provided as Photographs 1 -3 below.

Photograph 1: Koala detected in Bootland (Image 1 of 3)





5.4.4. Scat Identification Although some scats collected from the MPW development site were identified as 'probable' Koala scats as they did not display all the diagnostic characteristics, laboratory analysis of the scats by Ms. Story confirmed that the majority of the samples collected from the MPW development to be Koala scats. Despite the 'probable' diagnosis, the scats are assumed to comprise koala scats as they were found by a detection dog that is attuned to koala detection and is not trained for detection of alternate native fauna with similar scats.

5.4.5. Koala Occurrence in the Intermodal Precinct Although the scat data from the surveys implies that there is potential for more than one koala to be present within the Intermodal Precinct, it is also feasible that the single individual observed in the Bootland on 6 November 2018 (and potentially on the IR camera on 9 December 2018) is moving between the MPW site and the Bootland. Although Moorebank Avenue and the 1.8m high cyclone fence along existing work sites present barriers for movement, a culvert along Anzac Creek, running beneath Moorebank Avenue presents a possible fauna passage for koalas to move between the Bootland and the MPW site. All scats located within the MPW development area were restricted to a fragmented band of vegetation adjacent to the culvert opening. Although it is acknowledged that this observation is circumstantial and movement is further limited by existing cyclone fencing around the MPW site near the culvert, the potential for movement between the Bootland and the MPW development area through the culvert during dry periods cannot be fully discounted, especially as gaps at the base of the fencing were observed during the 18 September 2019 inspection (see Photograph 4).

Photograph 4: Fence conditions at MPW site near existing Anzac creek culvert (18 Sep 2019)


All available onsite survey data imply the presence of no more than 1-2 koalas within the Intermodal Precinct rather than a resident population. Based on recent koala studies in the Cumberland Plain area that indicate that shale-influenced koala habitat can support approximately 0.07 koalas/ha, it is possible that up to three koalas could potentially be sustained in the Bootland area.

The bushland areas within the Intermodal Precinct occur at the northern extent of a large area of bushland that is known to support Koala populations and includes the Holsworthy Military Reserve and areas within the Campbelltown LGA. Koala populations in the Campbelltown LGA are known to be recovering and currently expanding their Extent of Occurrence in the north and south-western areas of the LGA (Biolink 2016). Given this trend it is considered most likely that the koalas recorded on the Moorebank site are associated with this northerly expansion (Figure 6). Although the East Hills railway line forms a movement barrier between the Intermodal Precinct and the Holsworthy base, the presence of culverts beneath the railway line present potential fauna movement opportunities. During the December 2018 surveys conducted by Cumberland Ecology, gaps in the fence were observed at some locations around the Bootland which would further allow some movement into the Bootland.

Koalas have a complex social hierarchy based on a dominant male with a territory overlapping with that of several females with sub-ordinate males occurring on the periphery (OEH 2018a). The presence of culverts (fauna passages) and gaps in existing fencing would allow for some movement of koalas from adjacent bushland areas to the south to the south despite barriers from ongoing development in the locality. It is feasible that koala individuals were not recorded during surveys prior to 2018 due to either the absence of koalas at the time of survey or the presence of 1 - 2 individuals at low density of occurrence within the area.


This chapter presents general background information about the Koala. Information contained within this chapter includes key habitat requirements and threatening processes.

6.1. Key Habitat Requirements Koala habitat requirements are broadly described in the SEPP 44 – Koala Habitat Protection (SEPP 44) under the definitions of Core and Potential Koala Habitat. Core Koala Habitat is an area that contain a resident population of Koalas evidenced by breeding females, current sightings and historical records. Potential Koala Habitat is described as areas of native vegetation that contain feed tree species covering 15% of the upper or lower strata. These definitions suggest that feed tree species (as listed in Schedule 2 of the legislation) occurrence and density is the most important driving factor of Koala habitat suitability. Draft amendments to the SEPP 44 by the Department of Planning and Environment does however, encourage changes to these definitions based on Koala occurrence that imply a larger tree species list is required.

Similar to the SEPP 44, the Koala Profile on the OEH webpage (OEH, 2019b) and the Koala Recovery Plan for NSW (DECC, 2008) are consistent in describing that the occurrence of feed tree species is one of the most important factors in determining Koala habitat suitability. They do however, outline both primary and secondary feed tree species.

Due to the understood importance of feed tree species to habitat suitability to the Koala, a qualitative review was conducted to determine tree use patterns in order to model habitat across NSW. The results of this review was published in “A review of Koala tree use across New South Wales” prepared by OEH (OEH, 2018). The Review describes the use of a range of tree species outside of the Eucalyptus genus and in some instances appears to move away from referencing feed tree species – rather preferring the term ‘tree use’ to describe tree species that are important in determining habitat suitability. This results in a much more extensive list of tree species that assist in determining habitat suitability.

The Review determined that while koalas generally make use of a variety of tree species, whether for food, shelter or other purposes, within any location they typically display a dietary preference for a subset of tree species that may be considered of primary importance, with others used either for secondary browsing or as resting and shelter sites. Koala tree use (comprising food, shelter or other purposes) was standardised into four qualitative use levels: high, significant, irregular and low. Appendix 2 of the Review provided an updated status on trees considered to comprise food trees across NSW.

Further to tree use, the suitability of forest and woodland communities as habitat for Koalas can also be influenced by:

• Tree foliar chemistry;

• Soil type and moisture;

• Forest structure and tree size;

• Disturbance history;

• Landscape configuration; and

6. Koala Habitat Requirements and Threatening Processes


• Changes in climate and variability in temperature extremes.

Specifically, the Intermodal Precinct falls within a KMA (KMA 2) where the concepts of preferred Koala tree species are less well defined as areas of vegetation on comparatively high nutrient soils within the locality have been selectively cleared for agriculture. The KMA associated with the Intermodal Precinct contains the highest diversity of tree use across NSW.

6.2. Threatening Processes Section 9 of Koala Recovery Plan (DECC, 2008) lists the recognised current threats to the Koala as follows:

• Habitat loss and fragmentation;

• Habitat degradation;

• Road kills;

• Dog attacks;

• Fire;

• Logging:

• Disease;

• Severe weather conditions;

• Swimming pools; and

• Over-browsing.

Additionally, the following Key Threatening Processes listed under the BC Act are identified in the Koala Recovery Plan as potentially threatening to the survival of the Koala:

• Anthropogenic climate change;

• Clearing of native vegetation;

• Forest eucalypt dieback associated with over-abundant Psyllids and Bell Miners;

• High frequency fire resulting in the disruption of life cycle processes in plants and animals and loss of vegetation; and

• Predation by the European Red Fox (Vulpes vulpes).

The Koala Recovery Plan stipulates that any actions leading to the operation or intensification of impacts of a listed key threatening process need to be considered explicitly, in terms of the potential for significant impact on Koala populations (DECC, 2008). An assessment of impacts on MPW Stage 2 habitats, threatened communities and species, including the Koala, is provided in the BAR for the Project (Arcadis, 2019a). This KMP represents a supporting document to the BAR.


6.3. Conclusion The KTPs mentioned above that impact upon Koalas have been taken into consideration when formulating the mitigation measures for the Project. Chapter 8 details the mitigation measures proposed. Many of these impacts will be ameliorated within the MPW site and offset Areas.


7.1. Regional Perspective As mentioned previously, the Intermodal Precinct sits within KMA 2 (Image 2) as defined by ‘A review of Koala tree use across New South Wales.’ KMA 2 has been the focus of Koala survey and research centred around the Blue Mountains - Wollemi areas, as well as the Campbelltown, Wollondilly and Wingecarribee LGAs. Additionally, available records for the Koala within the broader Sydney area (as available on BioNet), indicate that koalas appear to be centred around the large tracts of remnant vegetation of Dharawal, Royal, Blue Mountains and Ku-Ring-Gai Chase National Parks.

Large tracts of bushland within the Holsworthy Military Barracks to the south of the Intermodal Precinct extend into the adjacent areas of the Campbelltown LGA (Figure 6), which supports one of the largest remaining koala populations in the Sydney region. The koala population of the Campbelltown LGA (the Campbelltown population) has been the focus of several scientific studies with data indicating that the population appears to be on a recovery trajectory in recent years. This recovery trend is supported by statistically significant increases in the Extent of Occurrence and Area of Occupancy by the Campbelltown population over at least the last three koala generations (Biolink, 2016). Recent studies of the Campbelltown population (Biolink, 2018) have confirmed ongoing range expansion associated with the ongoing recovery, with evidence of population expansion north past Long Point and therefore potentially into proximate areas of the Liverpool LGA.

Studies on koala food tree preferences in the Campbelltown LGA found preferential use of two species, Eucalyptus punctata and Eucalyptus agglomerata, on substrates derived from shales compared to those from sandstone (Phillips and Callaghan, 2000, Sluiter et al., 2002). This suggests that PKFT use is also influenced by differences in nutrient status between substrates and results in a requirement for large ranging patterns in low-nutrient environments.

The recovery of the Campbelltown population combined with the requirement for large home ranges and northward expansion suggests that the one or more individuals recorded within the Intermodal Precinct may comprise dispersing and/or wide-ranging individuals from the Campbelltown population to the south.

7.2. Koala Habitat and Records Several koala tree use species within KMA 2, as documented in ‘A review of Koala tree use across New South Wales’ occur within the MPW site and associated offset sites. However, as acknowledged in the Review, while koalas generally make use of a variety of tree species for food, shelter or other purposes, they display a dietary preference for a subset of tree species that may be considered of primary importance.

Therefore, based on the advice of Dr. Phillips the assessment of koala habitat for the purposes of this KMP has still largely been based on the presence of Preferred Koala Food Trees (PKFTs) for the region as it is the presence of PKFTs that largely determine the carrying capacity of a specific area to support Koalas. The PKFTs utilised within this KMP are based on a combination of food trees as defined in the Koala Recovery Plan, studies of the Campbelltown Koala Population and advice from Dr. Phillips with consideration to the updated list of food trees listed in Appendix 2 of the Review.

7. Distribution of Koala Population and Habitat


7.2.1. MPW site The native vegetation within MPW consists predominantly of remnant and regrowth vegetation that has been subject to weed invasion in some areas. Most of the vegetation is representative of endangered ecological communities listed under the BC Act.

Existing vegetation in the north-western, western and south-western parts of the MPW site has been mapped as ME018 Forest Red Gum – Rough-bark Apple grassy woodland on alluvial flats (Figure 7), with a canopy layer dominated by Eucalyptus tereticornis, Eucalyptus amplifolia and Angophora floribunda. The eastern to south-eastern parts the MPW site have largely been mapped as ME003 Hard-leaved Scribbly Gum – Parramatta Red Gum heathy woodland with some patches of ME005 Parramatta Red Gum woodland on moist alluvium near Anzac Creek (Figure 7). The canopy layer of ME003 is dominated by Eucalyptus sclerophylla, Eucalyptus globoidea, Eucalyptus parramattensis subsp. parramattensis and Melaleuca decora while the canopy of ME005 largely consists of Melaleuca linariifolia and Casuarina glauca with scattered occurrences of Eucalyptus parramattensis subsp. parramattensis.

In addition to the remnant native communities, planted trees are present in the road reserve adjoining Moorebank avenue.

The classification of trees recorded within the MPW site as PKFTs or other koala use trees is summarised in Table 3.

Table 3: PKFTs and other koala use trees recorded within MPW site

Species Common Name PKFT KMA 2 use level

Food tree status#

Angophora floribunda Rough-barked Apple Irregular No

Eucalyptus amplifolia Cabbage Gum High Yes

Eucalyptus baueriana Blue Box + Irregular Yes

Eucalyptus camaldulensis* River Red Gum * - Yes

Eucalyptus globoidea White Stringybark Significant Yes

Eucalyptus microcorys* Tallowwood * Significant Yes

Eucalyptus parramattensis subsp. parramattensis

Parramatta Red Gum + High Yes

Eucalyptus saligna x botryoides Hybrid Irregular (E.saligna) to Significant (E.botryoides)

No

Eucalyptus sclerophylla Hard-leaved Scribbly Gum

High No

Eucalyptus tereticornis Forest Red Gum + High Yes * indicates non-endemic planted species, is a PKFT in other KMA, not known as a PKFT in KMA2; # Food tree status as per NSW Planning and Environment 2016 column of Appendix 2 of the Review document


Koala scats were located in a patch in the south-eastern parts of the MPW development area. This vegetation comprises a narrow stretch of vegetation, occurring roughly parallel to Moorebank Avenue and has been mapped as a mix of ME003 Hard-leaved Scribbly Gum - Parramatta Red Gum heathy woodland (equivalent to Castlereagh Scribbly Gum Woodland TEC) and ME005 Parramatta Red Gum woodland on moist alluvium (equivalent to Castlereagh Swamp Woodland TEC). Scats were generally found at the base of either Eucalyptus parramattensis or Eucalyptus sclerophylla trees. This vegetation will be cleared as part of the MPW Stage 2 development resulting in no potential for Koala habitat or dispersal within the MPW site.

As outlined in Section 5.4.5 and Section 7.1, the recent evidence of Koala occurrence at the MPW site is considered to most likely comprise habitat use by one or more transient or dispersing individual(s) from the known Campbelltown population to the south, or from Koala movements from the Bootlands to the east via the Anzac Creek culvert under Moorebank Avenue.

Due to the nature of the approved MPW development, retention of PKFTs and other koala use trees within the MPW site is not being considered as koala usage of the MPW site is to be discouraged (See Section 7.4). However, all vegetation, including PKFTs and other koala use trees, within the offset (Biobank) areas will be retained with additional trees planted as required as part of the management actions under the approved Biobanking agreement BA 341 (OEH, 2019c).

7.2.2. Moorebank Offset Areas The majority of the vegetation within the Moorebank Offset Area consists of remnant vegetation that has been reported in the Biobanking Site Application prepared by WSP Parsons Brinckerhoff (WSP Parsons Brinckerhoff, 2017) as good to moderate condition.

The vegetation within the Moorebank Offset Area varied from patches with native species dominant in all vegetation layers to patches with the understorey and ground layer dominated by introduced vines and shrubs (e.g. Lantana camara, Privet spp. and Cardiospermum grandiflorum). The sites also included areas with dirt/gravel vehicle paths, small patches of bare ground with minimal vegetation and concrete pads.

Existing vegetation in the Moorebank Offset area has been mapped as ME018 Forest Red Gum – Rough-bark Apple grassy woodland on alluvial flats (Figure 7), with a canopy layer dominated by Eucalyptus tereticornis, Eucalyptus amplifolia, Eucalyptus baueriana, Eucalyptus saligna x botryoides, Angophora floribunda and Angophora subvelutina.

In addition to the native vegetation communities outlined above, Moorebank offset site contains areas consisting predominantly of introduced species. This exotic vegetation occurs as two vegetation types; exotic woody vegetation and exotic grassland. The exotic grassland areas are associated with riparian areas along the Georges River within the Moorebank Offset Area.

All native vegetation, including PKFTs and other koala use trees, is to be retained within the Biobank sites with further revegetation of exotic areas following weed removal.

The classification of trees recorded within the Moorebank offset site as PKFTs or other koala use trees is summarised in Table 4.


Table 4. PKFTs and other koala use trees recorded within the Moorebank Offset Area

Species Common Name PKFT KMA 2 use level Food tree status#


Eucalyptus amplifolia Cabbage Gum High Yes

Eucalyptus baueriana Blue Box + Irregular Yes

Eucalyptus crebra Narrow-leaved Ironbark High No

Eucalyptus fibrosa Broad-leaved Ironbark High No



Eucalyptus robusta Swamp Mahogany + High Yes

Eucalyptus saligna x botryoides

Hybrid Irregular (E.saligna) to Significant (E.botryoides)

No

Eucalyptus sclerophylla Hard-leaved Scribbly Gum High No

Eucalyptus sideroxylon Mugga Ironbark Significant No

Eucalyptus tereticornis Forest Red Gum + High Yes # Food tree status as per NSW Planning and Environment 2016 column of Appendix 2 of the Review document

No evidence of Koalas was recorded within the Moorebank Offset area during recent targeted surveys in December 2018. The vegetation, and by extension koala habitat, within the Moorebank offset area is to be managed and enhanced in accordance with the approved Management Action Plan for Biobanking Agreement BA341.

7.2.3. Bootland The majority of the vegetation within the proposed biobank site consists of remnant forest vegetation that has been reported by the Biobanking Site Application prepared by Parsons Brinckerhoff (WSP Parsons Brinckerhoff, 2017) to be of good to moderate condition.

The vegetation within the Bootland consists predominantly of remnant and regrowth vegetation that has been subjected to minor weed invasion in small areas. Areas of more intense weed invasion, where introduced species are dominant in the ground layer, are limited to the periphery of the site and along the existing disused rail spur that intersects the lower portion of the site. There is also a linear patch of regrowth vegetation that occurs to the north-east of the site which has been subjected to vegetation maintenance as a bush fire break and access track.

Vegetation within the Bootland (Figure 7) consists of a mix of the following communities:

• ME002 Broad-leaved Ironbark - Melaleuca decora shrubby open forest on clay soils of the Cumberland Plain, Sydney Basin Bioregion (dominant canopy trees: E.fibrosa, E.parramattensis, E.tereticornis);


• ME003 Hard-leaved Scribbly Gum - Parramatta Red Gum heathy woodland of the Cumberland Plain, Sydney Basin Bioregion (dominant canopy trees: E.sclerophylla, A.bakeri, E.parramattensis);

• ME004 Broad-leaved Ironbark – Grey Box – Melaleuca decora grassy open forest on clay/gravel soils of the Cumberland Plain, Sydney Basin Bioregion (dominant canopy trees: E. fibrosa, E. tereticornis);

• ME005 Parramatta Red Gum woodland on moist alluvium of the Cumberland Plain, Sydney Basin Bioregion (dominant canopy trees: E.parramattensis, E.sclerophylla, A.bakeri, A.floribunda, M.decora; and

• ME 007 - Coastal freshwater lagoons of the Sydney Basin Bioregion and South East Corner Bioregion.

All native vegetation, including PKFTs and other koala use trees, is to be retained within the Biobank sites with further revegetation of exotic areas following weed removal.

The classification of trees recorded within the Bootland as PKFTs or other koala use trees is summarised in Table 5.

Table 5. PKFTs and other koala use trees recorded within the Bootland

Species Common Name PKFT KMA 2 use level

Food tree status#


Eucalyptus eugenioides Thin-leaved Stringybark Irregular No

Eucalyptus fibrosa Broad-leaved Ironbark High No

Eucalyptus longifolia Woollybutt + High Yes



Eucalyptus resinifera Red Mahogany Significant No

Eucalyptus robusta Swamp Mahogany + High Yes

Eucalyptus sclerophylla Hard-leaved Scribbly Gum High No

Eucalyptus tereticornis Forest Red Gum + # Food tree status as per NSW Planning and Environment 2016 column of Appendix 2 of the Review document

Koala scats were found at the base of several trees across a large patch of vegetation comprising a mix of ME002, ME003 and ME005, in the southern parts of the Bootland during the detection dog surveys in December 2018. Scats were found at the base of a variety of tree species during Detection dog surveys including Eucalyptus parramattensis, Eucalyptus sclerophylla, Eucalyptus fibrosa, Angophora floribunda and Melaleuca decora. Koala scats were also detected within areas mapped as ME004 under a Eucalyptus eugenioides tree and a Eucalyptus fibrosa tree during Rapid SAT surveys. The IR camera recording of a koala also occurred within an area mapped as ME004.

The vegetation, and by extension koala habitat, within the Bootland is to be managed and enhanced in accordance with the approved Management Action Plan for Biobanking Agreement BA341 (OEH, 2019c).


7.3. Koala Habitat Ranking The carrying capacity of the vegetation communities to support koalas was ranked into the following categories based on the relative abundance of PKFTs within the community:

• Primary Habitat: Vegetation communities where Primary PKFTs (as per Table 1, Tables 4-5) comprise the dominant or co-dominant (i.e. ≥ 50%) overstorey tree species;

• Secondary Class A: Vegetation communities where Primary PKFTs (as per Table 1, Tables 4-5) are present but are not dominant or co-dominant (i.e ≤50% of overstorey tree species); and

Secondary Class B: Vegetation where Primary PKFTs are absent but secondary PKFTs (as per Table 1, Tables 4-5) are dominant/sub-dominant.

Based on the above ranking system the communities within the MPW site and offset areas are classified as:

i. Primary Habitat

• ME018 Forest Red Gum – Rough-bark Apple grassy woodland on alluvial flats of the Cumberland Plain, Sydney Basin Bioregion (E.tereticornis dominant); and

• ME002 Broad-leaved Ironbark - Melaleuca decora shrubby open forest on clay soils of the Cumberland Plain, Sydney Basin Bioregion (E.parramattensis and E.tereticornis ≥ 50% co-dominant).

ii. Secondary Class A

• ME003 Hard-leaved Scribbly Gum - Parramatta Red Gum heathy woodland of the Cumberland Plain, Sydney Basin Bioregion (E.parramattensis present but not ≥ 50% co-dominant);

• ME005 Parramatta Red Gum woodland on moist alluvium of the Cumberland Plain, Sydney Basin Bioregion (E.parramattensis present but not ≥ 50% co-dominant);

iii. Secondary Class B

• ME004 Broad-leaved Ironbark – Grey Box – Melaleuca decora grassy open forest on clay/gravel soils of the Cumberland Plain, Sydney Basin Bioregion (E.moluccana present and co-dominant);

The distribution of koala habitat rankings by vegetation community is shown in Figure 7.

For koala management purposes, each of the preceding habitat categories differ in terms of their potential koala carrying capacity, from High (Primary) to Low (Secondary B). This knowledge has ecological application in terms of assisting an understanding of the likely numbers of koalas that can be supported across a given landscape, but otherwise collectively constitute areas of Koala Habitat.

It is noted that the dominant and/or diagnostic species of the communities within the Moorebank offset site and the Bootland largely comprise trees classified as ‘High’ koala use for KMA 2 (see Table 4 and Table 5) with trees classified as ‘Significant’ or ‘Irregular’ for KMA2 comprising non-dominants or scattered occurrences.


High koala use trees within the Moorebank offset site and the Bootland that are also classified as ‘Food trees’ as per Appendix 2 of the Review are limited to Eucalyptus parramattensis and Eucalyptus tereticornis. These species dominate in ME018 and ME002 which corresponds to these two communities being mapped as ‘Primary Habitat’

Dominant trees in ME003 and ME005 comprise a mix of high koala use & ‘Food trees’ such as Eucalyptus parramattensis and high koala use trees that are not consided ‘Food trees’ in Appendix 2 of the Review such as Eucalyptus sclerophylla and Angophora floribunda which corresponds to these two communities being mapped as Secondary Class A. ME004 is dominated by Eucalyptus fibrosa (high use but not ‘Food trees’) with scattered occurrences of Eucalyptus tereticornis (high use and ‘Food tree’) which corresponds to this communities being mapped as a lower value habitat of Secondary Class B.

7.4. Koala Movement Corridors The M5 motorway, existing industrial development and lack of vegetation comprise a barrier to koala movement to the north of the Intermodal precinct while the Georges River presents a barrier to westward movement from the Intermodal Precinct. Areas east of the Intermodal Precinct comprise the residential area of Wattle Grove which largely lacks habitat for Koala movement.

The Georges River effectively separates the Casula offset area from other parts of the Intermodal Precinct for koalas. The Moorebank Offset Area and Bootland are currently separated by the MPW site, the MPE Site and Moorebank Avenue. The current barrier to east-west koala movement presented by Moorebank Avenue will be further expanded by the development of the MPE and MPW sites. The non-ecological requirements for the MPW and MPE site, in particular the security requirements to maintain a bonded site pose further barriers to fauna movement within the Intermodal Precinct.

While the existing Anzac Creek culvert currently presents a potential, albeit low quality, fauna movement corridor out of the Bootland under Moorebank Avenue, the future development of the MPW site, particularly in the area of the culvert outlet, will effectively close off this movement corridor.

Furthermore, the future realignment of Moorebank Avenue along the eastern boundary of the MPE site and along the easement to the south of Anzac Creek along with the proposed fencing for parts of the Bootland offset area on either side of the easement will effectively prevent/reduce fauna movement between areas of vegetation along Anzac Creek and the remainder of the Bootland. Therefore, the retention/enhancement of the existing Anzac Creek culvert under Moorebank Avenue as a koala movement corridor within the Intermodal Precinct is not considered to be viable.

Therefore, koala movement to/from other areas of koala habitat is limited to areas south of the Intermodal Precinct, i.e to/from vegetated areas of the Holsworthy Military Base. Although the East Hills Train line presents a barrier across the majority of the southern boundary of the Intermodal Precinct, potential movement corridors via existing culverts near the Bootland and under existing railway bridges are present at the southern boundaries of the Bootland and Moorebank Offset site respectively (Figure 8).

It is acknowledged that Condition B152(b) requires the provision of an adequate Koala habitat corridor to provide connectivity both within the Intermodal Precinct area and with other core koala habitat areas.


However, the current existing barriers and inherent requirements of the approved MPW and MPE development largely limit the extent of viable movement corridors to specific areas at the southern boundaries of the Moorebank offset area and the Bootland.

Condition B152 (d) requires elimination of barriers to movement (presented by fences, roads, drainage culverts or pits, rail lines and the like) for koalas and other native fauna likely to use the site or habitat corridor. Measures to enable fauna movement, including koala movement, through the proposed habitat corridor are outlined in Chapter 8.

As the MPE and MPW sites will comprise highly developed areas, fauna usage of the sites, once developed, is likely to be very low due to lack of habitat. Furthermore, the high volume of vehicular traffic, in particular rail traffic, within the approved MPE and MPW sites will pose a high strike risk for fauna, including koalas. Therefore, fauna use, including koalas, of the MPW and MPE development is to be discouraged via installation of barriers such as palisade fencing, to movement. The barriers are also consistent with the non-ecological security requirements for maintaining a bonded site.

Our conclusion regarding the lack of viable movement corridors to the north, west and east and within the Intermodal Precinct as well as placement of barriers to limit koala movement to the Moorebank offset area and Bootland is supported by Dr. Phillips.


8.1. Purpose The purpose of this chapter is to outline the mitigation and offset measures that are intended to ameliorate the impacts of the project on the Koala. The client has developed a number of offsetting measures to enhance Koala habitat.

As outlined in the BAR, the total MPW Stage 2 development area (referred to as the ‘Amended Proposal Site’ in the BAR) associated with the project is 167 ha. Of this area, approximately 28% (47 ha) will be located in areas mapped as comprising a native PCT. The BAR states that the vegetation to be impacted contains a relatively low site value score in comparison to the condition of the remnant vegetation within the offset sites.

Targeted surveys to date for the Koala have recorded limited activity in the south eastern portion of the MPW site. In contrast, recorded evidence of Koala activity is more extensive within the adjacent Bootlands site. Given the potential connectivity of the Bootlands site to known populations to the south, it is feasible that the Bootlands may be the northern limit of extant Koala territories.

However, as potential Koala habitat will be cleared from within the MPW site, mitigation measures are required as part of this KMP. The impact reduction measures for the Project relevant to the Koala are guided by the following hierarchy of principles:

• Avoid – to the extent possible, the project has been designed to avoid or minimise impacts to native vegetation (which comprises potential Koala habitat) by avoiding areas of high-quality habitat where feasible;

• Mitigate – where certain impacts are unavoidable through design changes, mitigation measures have been introduced to ameliorate the impacts to the Koala; and

• Compensate – the residual impacts of the MPW Stage 2 development, following the implementation of mitigation measures, have been compensated to offset what would otherwise be a net loss of Koala habitat. This includes the development of a Biodiversity Offsets Strategy (BOS) which includes land within and immediately adjacent to the MPW site, namely the Bootland and Moorebank Offset Sites.

Where possible, the MPW Stage 2 project will adopt and implement best practice measures to ameliorate and manage potential impacts on potential Koala individual(s) within the Intermodal Precinct.

8.2. Avoidance The Framework for Biodiversity Assessment (FBA) requires consideration of the steps taken to avoid and minimise the direct and indirect impacts of a development proposal on biodiversity values. Section 8.3.2 of the FBA sets out guidelines for the avoidance and minimisation of impacts to biodiversity during all phases of the project life cycle. The BAR has addressed these avoidance measures throughout each of the following phases of the project:

• Site selection phase;

• Planning phase;

8. Mitigation Measures


• Construction phase; and

• Operational phase.

Each of the preceding phases have included avoidance measures for native vegetation which forms the primary habitat for Koalas within the Intermodal Precinct.

8.3. Mitigation Measures This section summarises the proposed mitigation measures relevant to the Koala.

8.3.1. General Mitigation A suite of general environmental control measures will be implemented for the Project which will help to minimise impacts to the local population of the Koala. As part of the MPW Stage 2 development, the suite of management plans for construction and operational phases have been developed. Management plans of particular relevance to ecology and Koalas include:

• Construction Environmental Management Plan (CEMP);

• Operation Environmental Management Plan (OEMP); and

• Flora and Fauna Management Plan (FFMP) (which forms a sub-plan within the CEMP and OEMP).

This KMP forms a ‘sub-set’ of the FFMP and will largely be implemented in conjunction with the FFMP. Other management plans that will form part of the CEMP and OEMP that will have indirect benefits on ecology are summarised in Table 6.

Table 6. Summary of Proposed General Mitigation Measures

Mitigation Measures General Ecological Benefits

Dust minimisation Reduces the indirect impacts on vegetation condition and the habitat quality for all native species.

Noise minimisation Benefits fauna by reducing the potential for disturbance of animals in habitat patches around the Project.

Management of surface water, erosion and sedimentation

Protects the integrity of the landscape.

Visual and lighting management Benefits fauna by reducing the potential for disturbance of nocturnal animals via night light emissions around the Project.


8.3.2. Staged Clearing Process The 2019 BAR for the MPW Stage 2 development outlines several mitigation measures for ecology that will be included within the FFMP and CEMP. In particular, the proposed mitigation measures included a staged clearing process, including pre-clearing surveys and ecological supervision of clearing works. The general clearing protocols for fauna to be included in the FFMP are valid for Koalas.

However, clearing of native vegetation within the MPW Site will need to occur in a south to south-westerly direction to ensure that the individual Koala (if still present) is progressively encouraged to move into adjacent habitat areas of the Moorebank offset area. Areas delineated for clearance will be surveyed for Koalas as part of pre-clearance surveys prior to any clearance works taking place and will follow a minimum period of 24 hours to enable natural dispersal.

As habitat is progressively cleared, the Supervising Ecologist(s) will conduct further pre-clearance surveys to ensure that all animals are dispersing from the site. The underlying aims of these protocols will be to:

• Ensure no individual Koalas are present in any areas immediately prior to the commencement of any clearing of preferred Koala habitat;

• Discourage movement of Koalas into development areas by establishment of suitable barriers; and

• Ensure that all appropriate steps will be undertaken to avoid harm to any animal and minimise stress.

8.3.3. Dispersal of Koalas As previously outlined, available data provided evidence that suggested habitat use by no more than 1 - 2 koalas in the south-eastern corner of the MPW site; it is also more than likely that the presence of evidence of habitat use in this area is likely to be an extension of ranging activity from within the adjoining Bootland site. For this reason, the preferred method of dealing with a koala if sighted within the MPW site is one of assisted dispersal / relocation out of the development area (if required) rather than a formal translocation per se.

During the clearing process the following protocols should be followed:

• Should a koala be encountered within the development footprint during clearing activities, all work must cease within a radius of 50 m of the tree in which the koala is observed, with no further vegetation to the south to be removed until approved by the Supervising Ecologist; a minimum period that includes at least 1 night will be allowed to enable the koala to disperse naturally towards the Moorebank offset area; and

• If the koala is still present the following morning, it will be captured by individuals experienced in koala capture techniques, ideally either using a pole and flag technique or a koala trap and immediately relocated into the closest preferred food tree within either of the adjoining offset areas depending on location of capture.


8.3.4. Controlled Burns within Biobanks Sites The primary koala habitat to be retained within the Intermodal Precinct is contained within the approved Biobank sites. Management of the Biobank sites requires implementation of ecological burns for conservation.

The proposed burns comprise low intensity cool burns at a minimum frequency of 5 years. While these controlled burns do not comprise a significant hazard to koalas, the following protocols to minimise potential harm to koalas should be followed:

• Pre-burn spotlighting surveys of areas proposed for burning as well as adjacent areas should be conducted a few days prior to implementation of the controlled burn to determine presence of koalas in the immediate vicinity of the proposed burns; and

• Groundcover and/or litter around the base of PKFTs listed in Tables 3 - 5 and/or any tree in which a koala is sighted within the controlled burn site should be raked/removed to further reduce fire intensity.

It is noted that other threatened species dependent on leaf litter, such as the Cumberland Plain Land Snail, have been recorded in the Bootland. If individuals are found during removal of litter, they should be relocated to other suitable habitat trees within the Bootland, outside of the proposed controlled burn area.

8.3.5. Maintenance and Enhancement of Habitat Corridors Large areas of Koala habitat in the vicinity of the Intermodal Precinct that will be retained include those within the Bootland and Moorebank Offset Area. It is important that existing known or likely movement corridors be maintained and enhanced within the offset areas associated with Intermodal Precinct to allow Koalas to be able to disperse to adjacent areas and between habitat patches.

The Independent Planning Commission, as the consent authority, provided a number of conditions to be included in this KMP. It is stated in Condition B152 (b) that the KMP must:

“identify habitat corridors, of adequate dimensions to provide an adequate Koala habitat corridor as supported by a Koala specialist, to provide connectivity both within the Intermodal Precinct area and with other core koala habitat areas (i.e. to the south and to the west along Georges River).”

Currently, potential for connectivity between the Intermodal Precinct and adjacent habitat is mainly limited areas south of the Intermodal Precinct (see Section 7.4).

The following measures are to be implemented to maintain and enhance existing connectivity to koala habitats of the south of the Intermodal Precinct.

8.3.5.1. Fencing

As part of the Biobanking Agreement, all offset sites (and resultant koala habitat) will be largely be bordered by Cyclone fencing to maintain the ongoing security of the sites. This method of fencing has been approved by Dr. Phillips for being suitable Koala exclusion fencing. This fencing will ensure that Koala individuals cannot access areas adjacent to the Biobank sites that may be too hazardous due to development activities within the MPW and MPE sites and potential vehicle strikes on public roads.


Parts of the Moorebank offset site adjacent to the OSD basin channel outlets and under the newly constructed MPE Stage 1 rail link are to be fenced using rural fencing to allow for north-south fauna passage through the various sections of the Moorebank offset area (Figure 9).

The channel outlets leading to the Georges River will comprise sandstone channels with scattered habitat features to enable general fauna movement. The outlets are aligned with the creek or riverbanks to minimise the potential for bank scour and include energy dissipators designed in accordance with “The Outlet Structure Guidelines” published by the Department of Water and Energy and the Landcom Blue Book. A diagrammatic representation of the proposed channel design is shown in Image 3 below.

Image 3: Extract from the Stormwater Development Design Report SSD 7709, Draft 2 by Costin Roe, 23 October 2019

The channel outlets have been designed to maximise the potential for habitat connectivity and wildlife movement. It should be noted that as part of the BA314, the fauna passages have been designed for general fauna passage and not specifically for koala movement. Based on the variable discharge volumes and potential for flooding from the Georges River, koala movement is likely to be restricted to periods of low flow/dry conditions.

Although the presence of rural fencing comprises potential ‘gaps’ that would enable fauna movement towards the MPW site via the OSD basins (mainly during dry/low flow periods), the boundary of the MPW development site is to be fenced, using palisade fencing in accordance with the security requirements for a bonded site. As the palisade fencing will prevent any potential koala movement into the MPW site via the OSD basins, no further cyclone fencing around the OSD basins is proposed.


However, to prevent any potential koala movement into the MPW site, temporary cyclone fencing should be installed along the boundary of the MPW site until the palisade fencing is erected. This temporary fencing should be progressively erected following clearing works to ‘funnel’ any potential koalas within the MPW site towards the connectivity corridor under the MPE Stage 1 rail link (Figure 8).

8.3.5.2. Existing Culverts

There is an existing group of five culverts that run in a north-south direction underneath the East Hills Railway to the south of the Bootland (Figure 8) that would enable north-south connectivity between the Bootland and koala habitat areas to the south of the Intermodal Precinct. Although no measurements of the culverts were obtained due to access and safety limitations, visual assessments estimated the individual culvert entrances to be approximately 2 m high and about 4-5 m wide while review of aerial imagery determined an under-rail-line traverse of approximately 16-18m. Based on these assessments, the culverts were deemed by Dr. Phillips to exceed known minimum requirements for koala movement.

Advice from Dr. Phillips has indicated that these culverts may require some retro-fitting to ensure that they are suitable for all-weather Koala passage and minimise potential risk of movement into adjacent parts of the rail corridor (Photograph 5). Additional fencing to prevent movement along the rail corridor and funnel koalas towards the culvert will also be required at the northern and southern extents of the culvert. It is recommended that the ‘funnelling fences’ are placed adjacent to the two outermost culverts to encourage koala movement into the culverts.

However, as the culverts are within Railcorp Land, the retrofitting of the culvert and placement of funnelling fencing will depend on approval from Transport for NSW. Approval may also be required from Department of Defence to extend the connectivity corridor to the south of the Rail corridor as placement of koala bridges (Section 8.3.5.3) will also be required to enable koala movement. Following access approval, if granted by Transport of NSW and Department of Defence, the culverts and adjacent lands are to be assessed in detail to determine the extent and specific retro-fitting requirements and suitablity for placement of koala bridges to enable koala movement.

8.3.5.3. Koala Bridges

Two-way Koala bridges are to be used in conjunction with the Cyclone fencing for encouraging Koala passage in and out of the offset areas. Koala bridges are to be limited to the area of the culvert location to enable koala movement over the existing fencing (Figure 9). Koala bridges may also be required to enable koala movement under the section of the East Hills Rail bridge near the southern boundary of the Moorebank offset area if Railcorp and/or Defence land in this area is fenced off.

However, as construction of the koala bridges will require partial installation on RailCorp land and Defence lands, Transport for NSW and Department of Defence will need to be consulted prior to construction to gain necessary access/permits. Initial consultation with Transport for NSW (RailCorp) and Department of Defence to gain necessary access permission has been commenced. An indicative plan for the bridges is shown in Photographs 5 and 6.


Photograph 5: Westernmost of 5 culverts at the southern end of the Bootland

Photograph 6. Koala bridge design concept (side view)


Photograph 7. Koala bridge design concept (top view)

8.3.5.4. Koala Habitat Restoration

The Moorebank offset site and the Wattle Grove (Bootland) offset site are to be managed as Biobank sites under approved Biobank Agreement BA314. The following management actions for vegetation restoration are to be implemented under the Management Action Plan (MAP) associated with BA314:

• Weed control;

• Management of fire for conservation;

• Management of human disturbance;

• Retention of regrowth and remnant native vegetation;

• Replanting or supplementary planting (mix of direct seeding and tube stock) where natural regeneration is insufficient;

• Erosion control; and

• Control of feral animals and overabundant native herbivores

As the requisite management actions under BA314 will result in habitat restoration/rehabilitation of the identified habitat corridors within the boundaries of the Intermodal Precinct, no additional restoration actions beyond those required under BA314 are proposed as part of this KMP.

8.3.5.5. Limitations to Habitat Corridor Enhancement

The long-term functionality of the proposed koala habitat corridor on a landscape level will be dependent on obtaining access and permission to install the necessary enhancement structures on lands that are not owned by the client. In the event that permission is not granted by relevant landowners for installations of necessary structures to enable koala movement, there is high risk that the Bootland and Moorebank offset


area will effectively become isolated ‘islands’ of koala habitat, as fencing for the Biobank sites will prevent any future movement of koalas into the site from the culvert area. Under these circumstances, an alternative strategy for koala management to those proposed within this KMP will be required, a view that is supported by Dr. Phillips.

8.3.6. Koala-Grids The Biobank sites will have multiple tracks and access points to enable regular access for management purposes. Although these access points will be gated, koala grids should be installed near the gates and at main junctions to vehicular access tracks to discourage koala movement near these access points.

Koala-grids should be based on 60mm tubular steel pipe at 200mm centres at the locations indicated in Figure 9. Examples of currently approved Koala grids are shown in Photograph 7.

Photograph 8. Examples of Koala-grids

8.4. Direct Offsets The avoidance and mitigation measures described above would be insufficient on their own to ameliorate all anticipated impacts of the Project to the local Koala population. For this reason, offsetting is proposed to compensate for what would otherwise result in a net loss of habitat.

The approved Biobank sites largely address the offsetting requirements for vegetation removal from the MPW site and therefore Koala habitat. Nonetheless, as the Koala comprises a Species Credit Species under the FBA, a conservative approach was taken for the 2019 BAR and the Koala species polygon for the MPW


Stage 2 development encompassed all vegetation within the MPW site, resulting in a credit requirement of 1,110 koala credits.

As there are currently over 18,00 issued Koala credits on the biobanking public register, one or several of the current credit holders on the public register will be contacted to purchase the requisite number of koala credits for retirement against SSD-7709.


Monitoring of the Koala population and habitat will be a critical component of ongoing Koala management for the Intermodal Precinct. The implementation of this KMP also has the potential to provide a significant contribution to the existing information on the Koala, in particular for any population or individual occurring locally. As such, it is considered essential that the implementation of the KMP is monitored and the findings reported.

This chapter sets out the proposed monitoring and reporting associated within the implementation of this KMP.

9.1. Monitoring It is proposed that any Koala recorded within the Bootland and Moorebank Offset Area will be monitored in conjunction with other fauna monitoring commitments under the FFMP. Monitoring will be conducted annually in addition to the ongoing monitoring by the Environmental Officer or Supervising Ecologist.

Given the absence of Core Koala Habitat, small numbers of koalas based on survey data to date and uncertainly in the future extent of northern dispersal of the Campbelltown koala population, there is potential that use of habitat within offset areas by koalas will not be ongoing. Therefore, the primary intent of the monitoring program will be to inform changes in habitat utilisation by koalas within the Intermodal Precinct over the required time period. The objectives of the monitoring program will be to quantify any changes in baseline koala habitat use levels and monitor the effectiveness of the proposed mitigation and offset measures as outlined in Chapter 8.

Monitoring is proposed to occur at each of the field sampling points established for purposes of the Rapid-SAT assessment and will specifically be informed by the presence absence of koala scats at the base of PKFTs at these sites. Opportunistic observations of koalas will also be recorded. Mechanisms will also be put in place for adaptive management.

Prior to commencement of monitoring, an initial targeted assessment should be conducted across the biobank sites to better determine baseline Koala activity. Surveys should comprise a mix of spotlighting and Rapid-SAT surveys. If feasible, any scats present should undergo detailed genetic analysis to determine the number of Koalas that may be present within the biobank sites.

The finding of the initial targeted assessment will inform the refinement for a final field design for long-term monitoring. The final design is to be consistent with 95% - 99% Rapid-SAT assessment criteria requirements and will be reliant upon a 250 m survey grid. The final design will be submitted for approval prior to commencement of annual monitoring.

The Koala monitoring program will be implemented as soon as possible following the approval of this KMP and the final field design. The program will be funded by the client and will be managed as part of the Project. Data collected as part of the monitoring program will assist in determining the characteristics and changes in the occurrence of Koalas within the Intermodal Precinct and potential connectivity with the known Campbelltown Koala population to the south. The monitoring is initially to be conducted over a five-year period with requirements of on-going long-term monitoring to be determined at 5-yearly reviews of the monitoring program.

9. Monitoring and Reporting


The data collected during the monitoring program will be made available to relevant authorities to incorporate into any existing monitoring programs or databases. The general record collection process for the offset areas will be updated on an annual basis and contact will be maintained with relevant local, specialists and government authorities. The data collected as part of this KMP will significantly contribute to the knowledge base of the Koala population locally. Information will also contribute to the available research on the process and success of Koala relocation, if any is to be undertaken.

9.1.1. Rapid-SAT Plot and Spotlighting Surveys Population density and activity levels of Koalas will fluctuate over time. Following approval of a final design as mentioned above, all Rapid-SAT sites will be sampled within each offset area, with the following procedures undertaken at each plot:

• The centre of each Rapid-SAT site will be permanently identified by a suitably labelled star picket or other mechanism that enables the site to be located at each monitoring event.

• During each annual monitoring event, all details of any individual koalas observed will be documented, including health and tree species in which the individual is located;

• Descriptions of habitat, including recent disturbances and general vigour of vegetation and feed trees; and

• Recording of Koala scat presence/absence at the base of 7 nearest PKFTs as prescribed in the Rapid-SAT methodology.

The spotlighting transects will be based within the final SAT survey grid. Based on the final approved survey grid, spotlighting transects will be placed to enable sufficient replication to effectively survey ~ 25% of retained habitat at each survey event.

The monitoring grid will be focussed on the habitat within the offset areas contained within the Intermodal Precinct boundaries only. As parts of the proposed habitat connectivity corridor lie outside of lands owned by the proponent and comprise restricted access lands (i.e. RailCorp land, Holsworthy Military Base), monitoring of koala use of these areas is considered to be outside of the scope of this KMP.

The described sampling regime will be duplicated, initially on an annual basis, with the frequency of monitoring reassessed on the basis of the results after five years. The monitoring results and requirements will also be reviewed after each monitoring session. This method of monitoring has been found in other locations to be both very effective and an efficient means of reliable estimation of changes in the extent of habitat use by Koalas (S. Phillips, pers. comm.).

9.1.2. Reporting of Road Kills/Injuries A system of reporting of any road kills/injuries will be implemented so that all on-site personnel will be aware of the necessary procedures and the significance of such information. This reporting system will also extend to the sightings of any individuals within the Project Boundary and offset areas. Information to be recorded will include:


• Location of sighting/animal (location subsequently to be mapped);

• Status of animal (live in tree, injured etc);

• If injured/dead, cause of injury or death; and

• Identification of any relevant factors contributing to the status of the animal.

This information will then be used to incorporate appropriate measures into management strategies and other components of the monitoring program as required.

9.1.3. Habitat Monitoring Monitoring of Koala habitat and particularly of offset areas in conjunction with the Biobanking Agreement will also be undertaken. Given the time lag between the planting of seedlings and their suitability for use as habitat for the Koala, monitoring of the effectiveness of plantings is required. As plantings are to be conducted as part of management actions for the approved Biobanking Agreement (BA314), monitoring of the effectiveness of planting is to be conducted in accordance with the requirements of the Management Action Plan for BA314, in particular Sections 6.3 – 6.4 of Annexure C and Annexure D of the Management Action Plan.

The main criteria assessed for the habitat monitoring will comprise the following;

• Tree species composition (including juvenile specimens);

• Relative abundance of each species in tallest mid and lower (ground) stratum;

• General vigour of regenerating vegetation and vigour of plant stock (according to standardised vigour categories currently used for the threatened species monitoring program);

• Extent of new growth (according to standardised new growth categories currently used for the threatened species monitoring program);

• Age structure of vegetation; and

• Presence and degree of infestation of introduced weed species.

Sample plots will comprise permanent vegetation monitoring plots (20m x 20m) and will need to be located around the Rapid-SAT monitoring sites.

Habitat monitoring procedures will enable any problems associated with the development of the biobanking sites or with Koala habitat development as a whole to be detected at an early stage and appropriate ameliorative measures implemented. Such measures may include watering of plant stock during dry conditions, weed control and fire hazard reduction procedures. Management of such measures will be the responsibility of the Environmental Officer.


9.2. Reporting Monitoring will be conducted and reported upon annually for a 5-year period. The report will provide details of the methodology used and any variations for any sessions, the results and analysis of results and practical management recommendations. All responsibility for monitoring implementation, management procedures, reporting and associated costs will be held by the client. The monitoring report will be included in the Annual Review and made available to relevant authorities such as EES/DPIE and DoEE and will be published on the client’s website.

9.3. Implementation Roles and Responsibilities As stated in Section 8.3, this KMP forms a sub-plan within the wider FFMPs prepared for the Construction and Operational phases of SSD 7709. Therefore, the roles and responsibilities for the implementation of the KMP will largely be consistent with those of the FFMP. Broadly, the roles and responsibilities for the implementation of this KMP include:

Table 7: Roles and Responsibilities

Personnel Key Responsibilities

Principal’s Representative or Environmental Officer

Manage contractors for implementation of KMP, in particular Project Ecologist Review contractor reports and compliance documentation to confirm that the KMP is being implemented and remains adequate Oversee the implementation of management measures to enable the protection of native flora and fauna Take action to resolve KMP non-conformances, non-compliances and incidents as reported

Site Manager Direct works to be undertaken in an environmentally responsible manner that reduces impacts to flora and fauna Maintain exclusion zones and clearing limits Provide for adequate resources to enable the implementation of this KMP Deliver relevant training/inductions/toolbox talks to implement the requirements of this KMP

Project Ecologist Undertake preclearance surveys Be present during clearing works as required Provide specialist guidance as required Conduct surveys to establish ongoing monitoring design Consult with Koala specialist as required Undertake monitoring surveys

Koala Specialist Provide specialist advice/input as required

Contractors Implement management actions required under the KMP/CFFMP/OFFMP as directed by Environmental Officer or Project Ecologist. Works include, but are not limited to, bush regeneration, weed control, vegetation/tree removal, installation of signage, fencing and bush protection measures.


well as the Community Communication Strategy.Complaints handling will be undertaken in accordance with relevant sections of the CEMP and/or OEMP as

CEMP and/or OEMP.and/or Environmental Officer. All non-compliances are to be managed with the relevant sections of the All site personnel are responsible for reporting any non-compliances to the Site Manager/Site Supervisor

incidents will be managed and reported in accordance with the relevant sections of the CEMP and/or OEMP.is the responsibility of all personnel to report to the Site Manager/Site Supervisor. All environmental In the event of any environmental incident or unpredicted impacts that could affect koalas or koala habitat, it

9.5. Incidents, non-Compliance and Complaints

objectives and targets.environmental management performance and effectiveness of this plan against environmental policies, the CEMP and OEMP. Continuous improvement will be achieved by the ongoing evaluation of wider OEMP, review and improvement of this plan will be undertaken in accordance with the relevant sections of As this KMP forms a sub-plan within the wider FFMP, which in turn forms a subsection of the CEMP and

9.4. Review and Improvement


ARCADIS 2017. Sydney Intermodal Terminal Alliance (SIMTA) Moorebank Project East Stage 1: Biodiversity Assessment Report, dated October 2017.

ARCADIS 2019a. Moorebank Project West (MPW) Stage 2 Amended Proposal: Biodiversity Assessment Report. ARCADIS 2019b. Moorebank Project West (SSD-5066): EPBC Biodiversity Offset Strategy, dated May 2019. BIOLINK 2016. Analysing the historical record: aspects of the distribution and abundance of koalas in the Campbelltown City Council

Local Government Area 1900 – 2012 (Including an Appendix on Habitat Use and Classification): Report to Campbelltown City Council. Uki, NSW: Biolink Ecological Consultants,.

BIOLINK 2018. Review of koala Generational Persistence across Campbelltown City Council Local Government Area: 2012 - 2017. Uki, NSW: Biolink Ecological Consultants,.

DECC 2008. Approved Recovery Plan for the Koala (Phascolartos cinereus). Hurstville, NSW: Department of Environment and Climate Change.

OEH 2014a. Framework for Biodiversity Assessment. For assessing and offsetting state significant development and state significant infrastructure. Sydney: Office of Environment and Heritage for the NSW Government.

OEH 2014b. NSW Biodiversity Offsets Policy for Major Projects. Sydney: Office of Environment and Heritage for the NSW Government. OEH 2016. The Native Vegetation of the Sydney Metropolitan Area - VIS_ID 4489, Sydney, Office of Environment and Heritage. OEH 2018. A review of koala tree use across New South Wales. Sydney, NSW: Office of Environment and Heritage. OEH. 2019a. BioNet Atlas [Online]. Office of Environment and Heritage. Available:

http://www.environment.nsw.gov.au/atlaspublicapp/UI_Modules/ATLAS_/AtlasSearch.aspx [Accessed 2019]. OEH. 2019b. Koala - profile [Online]. Available: https://www.environment.nsw.gov.au/threatenedSpeciesApp/profile.aspx?id=10616

[Accessed]. OEH 2019c. Moorebank Intermodal Terminal Biobank Site: Biobanking Agreement (ID number BA341). PARSONS BRINCKERHOFF 2014. Moorebank Intermodal Terminal Project Environmental Impact Statement Volume 4: Technical Paper 3

Ecological Impact Assessment (with associated Biodiversity Offset Strategy). PHILLIPS, S. & CALLAGHAN, J. 2000. Tree species preferences of koalas (Phascolarctos cinereus) in the Campbelltown area south-west of

Sydney, New South Wales. PHILLIPS, S. & CALLAGHAN, J. 2011. The Spot Assessment Technique: a tool for determining localised levels of habitat use by Koalas

Phascolarctos cinereus. Australian Zoologist, 35, 774-780. PHILLIPS, S. & WALLIS, K. 2016. Koala Likelihood Mapping - Baseline Koala Survey Analysis and Reporting. Final Report to NSW

Environment Protection Agency. SIMTA 2018. Moorebank Precinct East Stage 1, Package 2: Construction Flora and Fauna Management Plan. SLUITER, A. F., CLOSE, R. & WARD, S. J. 2002. Koala feeding and roosting trees in the Campbelltown area of New South Wales. WSP PARSONS BRINCKERHOFF 2017. Biodiversity Assessment Report: Biobanking Agreement – Wattle Grove Offset Area (Part Lot 4 DP

1197707), Casula Offset Area (Part Lot 4 DP 1130937) and Moorebank Conservation Area (Part Lot 100 DP 1049508 and Part Lot 1 DP 1197707). Prepared for Moorebank Intermodal Company, dated February 2017.

10. References

http://www.environment.nsw.gov.au/atlaspublicapp/UI_Modules/ATLAS_/AtlasSearch.aspx

https://www.environment.nsw.gov.au/threatenedSpeciesApp/profile.aspx?id=10616

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APPENDIX A : Compliance with Conditions of Consent


Table 8: Independent Planning Commission – Ecological Conditions of Consent

IPC Condition consent Section of KMP where addressed

Condition B152. Prior to clearing of native vegetation, a Koala Management Plan (KMP) must be prepared by a suitably qualified person in consultation with the Office of Environment and Heritage (OEH) and be submitted to the Planning Secretary for approval. The KMP must:

Cumberland Ecology staff involved in the preparation of this KMP are fully trained and qualified ecological consultants. This KMP was prepared with expert input from Koala Specialist Dr. Steve Phillips

(a) make reference to ‘A review of koala tree use across New South Wales (OEH 2018)’;

Section 2.7, Section 4.1, Section 7.1, Section 7.2, Section 7.3

(b) identify habitat corridors, of adequate dimensions to provide an adequate Koala habitat corridor as supported by a Koala specialist, to provide connectivity both within the Intermodal Precinct area and with other core koala habitat areas (i.e. to the south and to the west along Georges River);

Section 7.4

(c) include commitment to retain Koala use trees on site in line with phased earthworks (see e.g. Condition B40);

Section 7.2.1

(d) include details of structures to eliminate barriers to movement (presented by fences, roads, drainage culverts or pits, rail lines and the like) for koalas and other native fauna likely to use the site or habitat corridor;

Section 7.4, Section 8.3.5

(e) include details on koala habitat rehabilitation/ restoration within the identified habitat corridors; and

Section 7.2.1, Section 7.2.2, Section 7.2.3. Section 8.3.5

(f) include other measures to minimise the risk of harm to koalas”.

Section 8.3.1 - Section 8.3.6

Condition B2 (i) identify habitat corridor/s, of adequate dimensions to provide an adequate Koala habitat corridor as supported by a Koala specialist, to provide connectivity both within the Intermodal Precinct area and with other core koala habitat areas, as required under Condition B152. The drawings are to show any required connectivity structures and fencing

Section 7.4, Figure 8, Figure 9

Condition B70 Boundary fencing design must allow for fauna movement where required under Condition B152(b).

Section 7.4, Section 8.3.5

Condition 155 The CFFMP must form part of the CEMP required by Condition C2

Section 8.3.1

Condition 160 Prior to commencement of operation an Operational Flora and Fauna Management Plan (OFFMP) must be prepared by a suitably qualified person in consultation with OEH and be submitted to the Planning Secretary for approval.

Section 8.3.1


IPC Condition consent Section of KMP where addressed

Condition C1: Management plans required under this consent must be prepared in accordance with relevant guidelines, and include:

(a) detailed baseline data; Chapter 3, Section 5.4, Chapter 7

(b) details of:

(i) the relevant statutory requirements (including any relevant approval, licence or lease conditions);

Chapter 2

(ii) any relevant limits or performance measures and criteria; and

Section 1.6, Appendix B

(iii) the specific performance indicators that are proposed to be used to judge the performance of, or guide the implementation of, the development or any management measures;

Section 8.2 - 8.4, Appendix B

(c) a description of the measures to be implemented to comply with the relevant statutory requirements, limits, or performance measures and criteria;

Chapter 8

(d) a program to monitor and report on the: (i) impacts and environmental performance of the development; (ii) effectiveness of the management measures set out pursuant to paragraph (c) above;

Chapter 9

(e) a contingency plan to manage any unpredicted impacts and their consequences and to ensure that ongoing impacts reduce to levels below relevant impact assessment criteria as quickly as possible;

Section 8.3.3, Section 8.3.5.3

(f) a program to investigate and implement ways to improve the environmental performance of the development over time;

Section 9.4

(g) a protocol for managing and reporting any: (i) incident and any non-compliance (specifically including any exceedance of the impact assessment criteria and performance criteria); (ii) complaint;

(iii) failure to comply with statutory requirements;

Section 9.5

(h) roles and responsibilities for implementing the plan; and Section 9.3

(i) a protocol for periodic review of the plan Section 9.4


Table 9: Commonwealth – Ecological Conditions of Consent

Commonwealth Condition Section of KMP where addressed

2. For the protection of the environment, including listed threatened species and communities, the person taking the action must prepare a construction environmental management plan (CEMP) addressing at least the elements outlined in Conditions 5 to 13. Apart from early works as described in Condition 3, construction must not commence until all specified CEMP approvals have been obtained in writing, and once approved, the CEMP must be implemented.

As outlined in Section 8.3.1, this KMP forms a specialised 'sub-set' of the Construction Flora and Fauna Management Plan, which in turn forms a sub-plan within the larger CEMP

4. For the protection of the environment, including listed threatened species and communities, the person taking the action must prepare an operational environmental management plan (OEMP) addressing at least the elements outlined in Conditions 5 to 13. Operations must not commence until all specified OEMP approvals have been obtained in writing, and once approved, the OEMP must be implemented.

As outlined in Section 8.3.1, this KMP forms a specialised 'sub-set' of the Operational Flora and Fauna Management Plan, which in turn forms a sub-plan within the larger OEMP

7. Sections of the CEMP and OEMP relating to biodiversity must be prepared by a suitably qualified expert and must: a) be consistent with the Biodiversity Provisional Environmental Management Framework (3 July 2014), provided at Appendix O to the finalised EIS b) incorporate all measures 6A to 6R, 6T, 6V and 6X from Table 7.1 of the finalised EIS that are described as ‘mandatory’ c) explain how all measures 6A to 6R, 6T, 6V and 6X from Table 7.1 of the finalised EIS that are described as ‘subject to review’ have been addressed d) include detailed biosecurity protocols, prepared in consultation with relevant New South Wales and Commonwealth biosecurity agencies, in relation to international and interstate container movement e) be approved by the Minister.

Section 2.1. Furthermore, as outlined in Section 8.3.1, this KMP forms a specialised 'sub-set' of the Construction/Operational Flora and Fauna Management Plan, which in turn form sub-plans within the larger CEMP/OEMP. As the discovery of koala occurrence within the site occurred after the issue of Commonwealth approval, Table 7.1 does not specifically address any requirements for koalas. Nonetheless, this KMP has been prepared as a specialised management plan in accordance with requirements for the NSW state approvals under the bilateral agreement for the FBA


Commonwealth Condition Section of KMP where addressed

Biodiversity offsets14. To address residual impacts on protected biodiversity values, including listed threatened species and communities, the person taking the action must finalise a biodiversity offsetstrategy (BOS). The BOS must be approved in writing within twelve (12) months of commencement of early works, by a relevant New South Wales regulator, and once approved must be implemented. The BOS must be prepared by a suitably qualified expert and must:a) be consistent with the biodiversity offsets strategy provided at Appendix E to the finalised EISb) incorporate all measures 6S, 6U, 6W and 6Y to 6AA from Table 7.1 of the finalised EIS that are described as ‘mandatory’c) incorporate all measures 6S, 6U, 6W and 6Y to 6AA from Table 7.1 of the finalised EIS that are described as ‘subject to review’ or justify any alternative protocolsd) offset impacts on protected biodiversity values including listed threatened species and communities in accordance with the FBA e) include map(s) and shapefiles that identify the location and boundaries of all offset sitesf) be approved by a relevant New South Wales regulator, and also by the Minister if the BOS does not involve the protection and management in perpetuity of the ‘Casula’,‘Moorebank’ and ‘Wattle Grove’ Offset Areas identified at Annexure 2.

Section 2.1, Section 8.3, Section 8.4

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APPENDIX B : KMP Management Actions


Table 10: KMP Management Actions and Responsibilities

Aim/Objective Relevant Phase Management requirement/ Performance Criteria

Responsible party

Assist in the dispersal of koalas potentially within approved development areas into adjoining offset areas

Pre-Construction/ Construction

Delineation of clearing limits Site Manager or nominated contractor


Alignment of clearing pathway Site Manager or nominated contractor


Pre-clearing surveys Project Ecologist

Undertake clearing activities in approved development areas in a manner that enables passive dispersal of koalas to occur (i.e. from north to south and south-west)

Construction Staged clearing Nominated clearing contractor

Construction Construction of temporary exclusion fencing of cleared areas to prevent fauna access

Nominated clearing contractor

Construction Clearing supervision Project Ecologist



Responsible party

Construction Stop works in event of Koala encounter Nominated clearing contractor, Project Ecologist

Construction Koala capture in event of individual not self-relocating

Project Ecologist, Koala specialist (advisory role)

Construction Establishment of Koala grids to limit koala movement outside of habitat corridors

Site Manager or nominated contractor

Facilitate maintenance of connectivity between the Intermodal Precinct and areas of koala habitat to the south of the Intermodal Precinct

Pre-Construction Access permits for areas outside of Intermodal Precinct

Principal/Environmental Manager

Construction/ Operational Habitat Enhancement/ Maintenance - Fencing Site Manager or nominated contractor

Construction/ Operational Habitat Enhancement/ Maintenance - Culvert retrofitting

Site Manager or nominated contractor; Environmental Manager (liason with relevant landholders)



Responsible party

Construction/ Operational Habitat Enhancement/ Maintenance - Koala bridges

Site Manager or nominated contractor; Environmental Manager (liason with relevant landholders)

Operational Habitat Enhancement/ Maintenance - Vegetation Restoration

Environment Manager, Site Manager and nominated Bush Regeneration Contractor

Biobank Site - Controlled Burns Operational Pre-burn koala surveys Project Ecologist

Operational Fuel load reduction around PKFTs or other nominated habitat

Site Manager or nominated contractor

Monitoring Pre-construction Initial surveys to establish monitoring grids Environment Manager, Project Ecologist

Operational Annual monitoring in approved monitoring grids

Environment Manager, Project Ecologist

Moorebank Precinct West Stage 2 Final | SIMTA Cumberland Ecology © Page C.3

APPENDIX C : Consultation with Regulators


Table 11: Responses to Environment, Energy and Science (EES) Group

Stake-holder

Initial Date

Screenshot of typo and/or other issues

Proponent Response Initial Response Date

Reviewer Comment on Response

Proponent further response

Condition B152(a): The KMP must make reference to A review of koala tree use across New South Wales (OEH 2018)

EES (OEH)

14/11/19

While reference is made to the OEH 2018 document, the KMP states that the assessment of koala habitat (or the determination of the potential carrying capacity of specified areas to support koalas) in the Precinct was based on the presence of preferred koala feed trees (PKFTs) as advised by the koala specialist, Steve Phillips. EES Group is concerned that koala habitat in the precinct is not based on the longer list of trees included for the Central Coast Koala Management Area (KMA) in the OEH 2018 document (as stated in Table 1). EES Group notes that species considered in the KMP as PKFTs include: Eucalyptus tereticornis Eucalyptus parramattensis Eucalyptus microcorys Eucalyptus robusta

The Koala Specialist, Dr Steve Phillips advised that, “The report by OEH (2018) reflects a commendable effort to review tree use by koalas but remains fundamentally flawed by an over reliance upon anecdotal and qualitative assessments to assign importance rankings. Within the Central Coast KMA this assertion can be most readily evidenced by Silvertop Ash E. sieberi. Promoted as a ‘high use’ species by the OEH (2018) report (despite substantive field-based SAT data to the contrary), more recent work by Au et al. (2019) – A nutritional mechanism underpinning folivore occurrence reported that koala density and the presence of E. sieberi were inversely correlated (i.e. the more E. sieberi there were,

20/11/2019 EES Comments received 29/01/2020 EES Group does not agree with the example cited by Dr Phillips as proof that the OEH report is ‘fundamentally flawed’. While it is acknowledged that E. sieberi is not a high-use tree, data from recent radio-tracked koalas confirms this tree is used by koalas. It is noted the statistical criteria referenced in the draft report cited by Dr Phillips for determining PKFTs is not a published or peer-reviewed and should therefore not be relied upon to justify feed or high-use koala trees. EES Group also notes the comment by Dr Phillips that

Response to EES Comments received 29/01/2020 Dr. Phillips notes that the criteria by which PKFTs can be identified have been published, Phillips et al (2000) while Phillips and Callaghan (2000) describe the levels of utilisation for Secondary PKFTs. It is noted that both these documents are referenced in the OEH 2018 Review document. Of relevance is that the work identifying both the most preferred food trees


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Initial Date





Eucalyptus moluccana Eucalyptus longifolia Eucalyptus baueriana Eucalyptus punctata (although this species was noted as not occurring in the site)

the less koalas there were). Given uncertainties created by the OEH (2018) report, statistical criteria required to be satisfied in order for a given Eucalyptus spp. to qualify as a Preferred Koala Feed Tree species (PKFTs) have recently been prescribed in an unrelated report for OEH (Draft NSW Survey Guide for the ‘Species Credit’ koala (Phascolarctos cinereus) – Appendices 2& 3 refer). It should be noted that the KMP has already taken a precautionary approach to the matter of PKFTs on the site. Specifically, E. microcorys is acknowledged as a PKFT but its presence on the site is not a natural occurrence but as a result of plantings. Despite its importance as a PKFT in KMA 1, and that it is widely planted in the Sydney basin, there is no evidence that koalas in the Central Coast KMA recognise this species as a

the KMP takes a precautionary approach for E. microcorys as a PKFT (despite the view that koalas in this area do not use E. microcorys). However, this precautionary approach is not applied to other trees present which are highlighted as high-use, significant-use, or locally important in plans/reports/ papers. EES Group considers a precautionary approach to PKFT should be consistently applied to all species known to be used by koalas.

and the nature of their use by koalas was undertaken in the Campbelltown area and is thus of direct relevance to the KMP. It is not disputed that koalas utilise trees other than PKFTs, only that they are not preferentially utilised. Nonetheless, the KMP has been updated to expand ‘koala tree use’ to include the classifications of koala tree useage as per the OEH 2018 Review document. This is largely addressed in Sections 7.2 and 7.3 with minor additions in sections 2.7 and 6.1.


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food tree”. EES Comments received 28/02/2020 EES Group is aware of these papers, however, it is the citing provided by Dr Phillips to justify the identification of a PKFT that is questioned i.e. ‘… an unrelated report for OEH (Draft NSW Survey Guide for the ‘Species Credit’ koala (Phascolarctos cinereus) – Appendices 2& 3 refer)’. While noting the KMP has been updated to include ‘koala tree use’ trees, the PKFT list has not been amended. Given the assessment of koala habitat is still based on the original PKFT list, the habitat rankings remain unchanged. EES Group does not agree with these rankings and reiterates the view that all vegetation

Response to EES Comments received 28/02/2020 The list of PKFTs within the KMP was based on a combination of known food tree species (as listed in the Koala recovery plan) recorded within the Intermodal Terminal site, studies of the Campbelltown koala population and expert input from Dr. Phillips. Although Eucalyptus punctata and Eucalyptus agglomerata were not recorded within the Intermodal Terminal, Eucalyptus punctata


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types are high quality (or are ‘primary habitat’ if using the KMP’s classifications)

was nonetheless included as a PKFT as it can occur as a secondary canopy species within the vegetatation communities recorded within the Intermodal Terminal site. It is noted that initial comments from EES group listed the following species for consideration as PKFTs Eucalptus amplifolia; Eucalyptus globoidea; Eucalyptus eugenoides; Eucalyptus fibrosa; and Eucalyptus sclerophylla. Eucalyptus amplifolia


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was not included as a PKFT despite listing as a primary feed tree for the Central Coast KMA in the Koala recovery plan and as a feed tree in the OEH Review document on advice from Dr. Phillips. Nonetheless, this species has only been recorded within ME018 which has been classified as Primary habitat within the KMP. Eucalyptus globoidea is listed as a supplementary species for the Central Coast KMA in the Koala recovery plan and was not included as a PKFT despite listing as a


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feed tree in the OEH Review document on advice from Dr. Phillips. Eucalyptus eugenoides, Eucalyptus fibrosa and Eucalyptus sclerophylla are not considered feed trees in the OEH Review document and only Eucalyptus eugenoides is considered to be a supplementary species for the Central Coast KMA in the Koala recovery plan. Therefore, these species were not considered as PKFTs. Based on the above consideration of species recommended by EES


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group, the original PKFT list and corresponding habitat classifications/ rankings have not been amended. It is noted that at the closing out of consultation, a difference of opinon remained between Dr. Phillips and EES on what constitutes a PKFT. This KMP has retained the advice of Dr. Phillips with regard to the definition of a PKFT based on his experience and expertise on koalas, including recognition as a koala expert by the Environment Agency Head under


Stake-holder

Initial Date





Section 6.5.4.2 of the Biodiversity Assessment Method

EES (OEH)

14/11/19

While the KMP states that the koala specialist based his determination of PKFTs on listed trees in the Koala Recovery Plan (Central Coast KMA), SEPP44, and local studies of Campbelltown koalas (as noted in Sluiter et al. 2002; Phillips and Callaghan 2000), EES Group’s review of listed trees in the Koala Recovery Plan and local studies found there were a number of species omitted as PKFTs in the KMP. This selectivity was not justified in the KMP: species specifically noted as being present in the Intermodal Precinct that are in the Koala Recovery Plan list and not included as PKFTs are E. amplifolia, E. eugenoides and E. globoidea. The Koala Recovery Plan for the Central Coast KMA identifies E. amplifolia as a primary food tree

Dr Steve Phillips advised that, “The intent of specialist input was to ensure that the most up-to-date knowledge of habitat use / tree selection by koalas was taken into account. Available data collected since the KRP was approved has unequivocally established that E. amplifolia is not amongst the suite of PKFTs, while the stringybarks E. eugeniodes and E. globoidea are listed by the KRP as ‘supplementary’ food tree species only (as opposed to Primary and Secondary food tree species which otherwise comprise the suite of PKFTs most important for management purposes). Like E. sieberi, available field data confirms that E. fibrosa (in common with all ‘Ironbarks’) is

20/11/2019 EES Comments received 29/01/2020 EES Group is not aware of the data Dr Phillips references regarding tree habitat use/tree selection. EES Group data collected from local koala radio tracking over the last year confirms E. globoidea (as well as other stringybarks) are used by koalas at high frequency. This data also indicates that E. fibrosa is used less often, but one radio-tracked koala was recorded using this species close to 10% of the time. EES Group does not concur with the assertion of Dr Phillips that ‘ironbarks’ are not used by koalas.

Response to EES Comments received 29/01/2020 As per preceding response


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species, and E. eugenoides and E. globoidea as supplementary species. species specifically noted as being present in the Intermodal Precinct that are important from local studies that are not included as PKFTs are E. fibrosa, E. eugenoides, and E. globoidea. The species E. agglomerata is also important from local studies, but it is not clear whether this species is present on the site.

NOT a PKFT because its use by koalas is demonstrably opportunistic and/or associated with proximity to PKFTs.

EES (OEH)

14/11/19

The KMP does not clearly justify why trees such as E. fibrosa, E. sclerophylla and E. eugenoides in particular are not considered in the KMP as PKFTs. It is noted Koala scats were found beneath these species within the Bootland offset site and MPW Stage 2 area during koala surveys. All three species are identified in the OEH 2018 document: E. sclerophylla as a high-use tree, E. fibrosa as a significant-use tree, and E. eugenoides as an irregular-use tree.

Dr Steve Phillips advised that, “Preceding comments refer. There is no evidence from available survey data that neither E. sclerophylla (or any scribbly gum for that matter) nor E. fibrosa or E. eugenoides are PKFTs by definition. Relevant Central Coast KMA field survey results published in the peer-reviewed literature (Phillips and Callaghan 2000 Tree species preferences of koalas in the Campbelltown area … and

20/11/2019 EES Comments received 29/01/2020 EES Group accepts that koala scats under a tree does not automatically confer PKFT status. It does, however, indicate tree use (and possible feeding). EES Group notes that despite acknowledgement in the KMP that local studies found a preference for Eucalypt species ‘on substrates derived

Response to EES Comments received 29/01/2020 As per previous response Furthermore the KMP has been updated to largely remove references to soil types as these have not specifically been utilised to rank koala habitat.


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Sluiter et al. 2002 – Koala feeding and roosting trees in the Campbelltown area…) have also not found Scribbly Gums and Ironbarks to be the subject of significant levels of utilisation by koalas. The presence of koala scats beneath a tree does not automatically confer PKFT status (please refer to Phillips et al. 2000 – Tree species preferences of koalas inhabiting forest and woodland communities on Quaternary deposits in the Port Stephens area…) for a more detailed discussion of this issue in terms of how PKFTs influence the use of other (non-PKFTs) in immediate area”.

from shales compared to those from sandstone’, soil type is not applied at any stage to rank habitat. EES Group’s view, based on available published data and recent studies, is that all vegetation types on enriched soils that contain trees koalas have demonstrated to use should be considered equally important habitat.

Condition B152(b): The KMP must identify habitat corridors, of adequate dimensions to provide an adequate Koala habitat corridor as supported by a Koala specialist, to provide connectivity both within the Intermodal Precinct area and with other core koala habitat areas (i.e. to the south and to the west along Georges River)

EES (OEH)

14/11/19

The KMP does not provide connectivity via habitat corridors

Confirmed and Noted 20/11/2019 n/a


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within the Intermodal Precinct area (i.e. between and within MPW and MPE development areas). The KMP states that current existing barriers and inherent requirements of the approved MPW and MPE development prevent connectivity within the Intermodal Precinct area - EES Group concurs with this assessment.

EES (OEH)

14/11/19

The KMP provides connectivity within the Moorebank (Georges River) offset site and within the Wattle Grove (Bootland) offset site.

Confirmed and Noted 20/11/2019 n/a

EES (OEH)

14/11/19

The KMP provides connectivity between the southern boundary of the Moorebank (Georges River) offset site and Holsworthy Military Barracks. According to the KMP, koalas will be able to move between these areas under the East Hills rail line and under the MPE Stage 1 rail link. The KMP notes that should Railcorp or Defence install any fences, a bridge will need to be installed and

Noted 20/11/2019 EES Comments received 29/01/2020 Noted

Response to EES Comments received 29/01/2020 n/a


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permits/access will need to be obtained from Railcorp or Defence.

EES (OEH)

14/11/19

The KMP provides connectivity between the southern boundary of the Wattle Grove (Bootland) offset site and Holsworthy Military Barracks. According to the KMP, koalas will be able to move between these areas via culverts that lie under the East Hills rail line, and bridges built over fences (the boundary fences of the Wattle Grove offset site and Holsworthy Military Barracks). EES Group notes that only bridges across the boundary fence of the Wattle Grove offset site is shown in Figure 9 (bridges across the boundary fence of Holsworthy Military Barracks is not shown). The KMP states that koala bridges will require permits/access from Railcorp and/or Defence – these have not been obtained.

Noted 20/11/2019 EES Comments received 29/01/2020 Noted


EES (OEH)

14/11/19

The KMP does not specifically state that koalas could access both the

Noted. We also agree that this is possible but it was considered

20/11/2019 EES Comments received 29/01/2020

Response to EES Comments received


Stake-holder

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Moorebank (Georges River) offset site and the Wattle Grove (Bootland) offset site via Holsworthy Military Barracks, but EES Group notes this is possible.

beyond the scope and focal area of the KMP.

EES Group recommends the KMP be amended to acknowledge the potential for koala access to the offset sites via Holsworthy Military Barracks.

29/01/2020 Section 7.4 (pg 38) acknowledges potential for movement to/from Holsworth Military Barracks.

EES (OEH)

14/11/19

The KMP does not provide any information on the dimensions of habitat corridors between the southern boundaries of the two offset sites and Holsworthy Military Barracks. It appears from Figure 8 that the connection between the Moorebank (Georges River) offset site and Holsworthy Military Barracks may be adequate (approximately 20m wide). Also, that the five culverts between the Wattle Grove (Bootland) offset site and Holsworthy Military Barracks are wide enough for koalas to move through, though characteristics of the culverts are not provided.

Noted. Dr Steve Phillips advised that: “The five culverts were observed from the most proximal advantage point along the southern boundary of the Bootland offset site. No measurements were obtained on safety grounds but given the short under-rail-line traverse that was required (< 20m), coupled with estimated dimensions of the individual culverts (4 – 5 m wide, 2 m high), they were deemed to exceed known minimum requirements for koalas”.

20/11/2019 EES Comments received 29/01/2020 EES Group recommends the KMP be amended to incorporate advice from Dr Phillips.

Response to EES Comments received 29/01/2020 Section 8.3.5.2 has been updated to provide culvert dimension estimates and advice from Dr. Phillips


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EES (OEH)

14/11/19

The KMP notes that a koala specialist, Steve Phillips, supports the areas of allowed connectivity, though he suggested culverts linking the Wattle Grove (Bootland) offset site and Holsworthy Military Barracks may require some retrofitting.

Acknowledged. Retro-fitting of the culverts with elevated ledges or walkways on the landward side of the last culvert at both ends of the series of 5 should be considered in order to enable year-round utility in the event they become inundated.

20/11/2019 EES Comments received 29/01/2020 EES Group recommends the KMP be amended to clearly state culverts will be investigated to determine their need for retrofitting, with approval sought from Transport for NSW and Department of Defence. EES Group notes the KMP states initial consultation has commenced with Transport for NSW and Department of Defence regarding koala bridges.

Response to EES Comments received 29/01/2020 Section 8.3.5.2 has been updated to specify further investigation of culverts following receipt of relevant landholder permits

EES (OEH)

14/11/19

The KMP does not specifically provide connectivity between the Moorebank (Georges River) offset site and the Casula (Hourglass) offset site. These two offset sites are naturally separated by the Georges River.

Noted 20/11/2019 EES Comments received 29/01/2020 Noted.


EES (OEH)

14/11/19

The KMP commits to clearing koala habitat in the MPW development area in a staged process, from north to

Dr Steve Phillips advised that: “This is an important management measure intended to assist a

20/11/2019 EES Comments received 29/01/2020 Noted

Response to EES Comments received 29/01/2020


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south and south-west to ensure that any koalas present are progressively encouraged to move into adjacent habitat areas of the Moorebank (Georges River) offset area.

passive dispersal of any koalas that may be present in the site at the time of clearing, into the adjoining offset area”.

n/a

EES (OEH)

14/11/19

The KMP commits to retain all koala use trees within the offset areas. The KMP does not define koala use trees at any point. The KMP only defines PKFTs.

Dr Steve Phillips advised that: It is the presence of PKFTs that enables koala use of the site to persist. The KMP has been updated and use of the term ‘koala use trees’ is limited to Sections where the wording of the Consent Conditions is quoted verbatim.

20/11/2019 EES Comments received 29/01/2020 It is not apparent the KMP has been updated to address this issue.

Response to EES Comments received 29/01/2020 Sections 7.2.1 – 7.2.3 have been updated to specifically state that no vegetation (including PKFTs and other koala use trees) will be retained in the MPW site but all vegetation (including PKFTs and other koala use trees) will be retained within Biobank sites.

Condition B152(d): The KMP must include details of structures to eliminate barriers to movement (presented by fences, roads, drainage culverts or pits, rail lines and the like) for koalas and other native fauna likely to use the site or habitat corridor

EES (OEH)

14/11/19

The KMP includes information on rural fences (5-strand plain wire

The channel outlets have been designed to maximise the potential

20/11/2019 EES Comments received 29/01/2020

Response to EES Comments received


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fences) that will be placed at channel outlets from the MPW development area to the Georges River, adjacent to the Moorebank offset site. Information states that the rural fences will have enough gaps to allow koalas passage to move across the channel outlets that cut across the Moorebank offset site, and these appear suitable in allowing koala movement. Little information is provided on the channel outlets themselves (other than they are comprised of sandstone channels with scattered habitat features) and whether koalas can traverse these.

for habitat connectivity and wildlife movement. It should be noted that as part of the BA314, the fauna passages have been designed for general fauna passage and not specifically for koala movement. Based on the variable discharge volumes and potential for flooding from the Georges River, the KMP acknowledges that koala movement is likely only in low flow/dry conditions. The outlets are aligned with the creek or riverbanks to minimise the potential for bank scour and include energy dissipators designed in accordance with “The Outlet Structure Guidelines” published by the Department of Water and Energy and the Landcom Blue Book.

EES Group recommends the KMP be amended to include the additional information in the proponent response.

29/01/2020 Section 8.3.5.1 has been updated to include the additional information in the proponent response.


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Extract from the Stormwater Development Design Report SSD 7709, Draft 2 by Costin Roe, 23 October 2019.

EES 14/11/ The KMP states that culverts are See comments in response to 20/11/2019 EES Comments received Response to EES


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(OEH) 19 present beneath the East Hills rail line allowing koala movement between the Wattle Grove offset site and Holsworthy Military Barracks. Little information is provided on the culvert characteristics. The KMP notes its koala expert’s comment that culverts may require some retrofitting to make these more favourable for use by koalas.

Condition B152 b above 29/01/2020 As above.

Comments received 29/01/2020 As above

EES (OEH)

14/11/19

The KMP provides information on koala bridges that would be used by koalas to cross fences - these appear suitable.

Noted 20/11/2019 - n/a

Condition B152(e): The KMP must include details on koala habitat rehabilitation/ restoration within the identified habitat corridors

EES (OEH)

14/11/19

The KMP refers to management actions to manage and enhance koala habitat within the offset areas under the approved Biobanking agreement, BA 341.

Noted 20/11/2019 - n/a


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EES (OEH)

14/11/19

The KMP does not specifically refer to habitat restoration/rehabilitation in the identified habitat corridors between: the Moorebank (Georges River) offset site and habitat to the south in Holsworthy Military Barracks the Wattle Grove (Bootland) offset site and habitat to the south in Holsworthy Military Barracks

Habitat restoration and weed management are already required to be implemented as part of the approved Biobank agreement (BA314) and includes planting of PKFTs (E.tereticornis and E.parramattensis) in restoration areas. Section 7.2.2 and 7.2.3 of the KMP states that vegetation in the offset areas (and by extension koala habitat) was to be managed as part of BA314. New Section 8.3.5.4 mentions this again. Given that BA314 is approved and EES have the agreement on record further details on habitat restoration/rehabilitation are not provided within the KMP.

26/11/2019 Response to EES Comments received 29/01/2020 Noted


Condition B152(f): The KMP must include other measures to minimise the risk of harm to koalas


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EES (OEH)

14/11/19

The KMP includes measures to minimise the risk of harm to koalas from controlled burns in the Moorebank (Georges River) and Wattle Grove (Bootland) offset sites, though there is no direction on actions to take if pre-burn surveys reveal the presence of a koala.

Noted. Section 8.3.4 of the KMP has been amended accordingly.



EES (OEH)

14/11/19

Other measures provided by the KMP to minimise the risk of harm to koalas are those already required as part of the development i.e. dust and noise minimisation, management of surface water, erosion and sedimentation, and light management.

Noted 20/11/2019 - n/a

EES (OEH)

14/11/19

In Chapter 2, the KMP outlines matters that are required to be considered when preparing individual KMPs in accordance with SEPP44 Circular B35. Amongst other matter, this includes: an estimate of population size, identification of preferred feed tree

The following text has been included in Section 1.3 and Section 5.4.5 of the KMP. Section 1. 3 and Section 5.4.5 have been amended to address population size. Note that Table 2 of SEPP44 lists

26/11/2019 EES Comments received 29/01/2020 EES Group estimates from recent survey data that shale-influenced koala habitat in the local area supports approximately 0.07 koalas/ha. As such, it is estimated that up to three koalas could be

Response to EES Comments received 29/01/2020 Section 1.3 and Section 5.4.5 have been updated to mention potential carrying capacity based on the


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species for the locality and the extent of resource available, aims of the plan, criteria against which achievement of aims are to be measured. The KMP does not adequately address the above regarding the extent of resource available.

food tree species listed. Legally, these are the only tree species that have standing for purposes of the KMP (i.e. EES tree review DOES NOT have standing for purposes of SEPP). Section 1. 6 addresses Purpose and Aims of the plan

sustained in the Bootland area. It is recommended that the additional text in sections 1.3 and 5.4.5 regarding population size be amended to reflect this. In relation to the note regarding koala food tree species listed in table 2 of SEPP44, EES Group notes SEPP44 will be replaced by State Environmental Planning Policy (Koala Habitat Protection) 2019 on 1 March 2020 (https://www.planning.nsw.gov.au/Policy-and-Legislation/Environment-and-Heritage/Koala-Habitat-Protection-SEPP). The list of koala feed tree species in the Koala Habitat Protection SEPP (schedule 2) significantly expands the very limited list in SEPP44 and largely mirrors the ranked

provided information. A new Section 2.5.1 has been added to acknowledged that SEPP44 is soon to be replaced and that the new Koala Habitat Protection SEPP significantly expands the list of koala tree species from 10 to 123. As the Koala Habitat Protection SEPP is currently not in force and Condition B152 (a) specifies that the KMP is to reference the 2018 OEH review document, the KMP has been updated to incorporate the koala tree use rankings (Table 3) and updated Koala food tree list

https://www.planning.nsw.gov.au/Policy-and-Legislation/Environment-and-Heritage/Koala-Habitat-Protection-SEPP






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canopy trees in A review of koala tree use across New South Wales (OEH 2018) which the KMP must reference in accordance with consent condition B152(a).

(Appendix 2) of the review document. Relevent updates to the KMP are in Sections 2.7, 6.1, 7.2 and 7.3 + Tables 1, 4 and 5.

EES (OEH)

14/11/19

Despite the KMP stating that the assessment of koala habitat is based on PKFTs, Chapter 7.2 appears to rank koala habitat (or areas with higher potential carrying capacity to support koalas) based on vegetation types. EES Group does not have a problem with ranking koala habitat on vegetation types in general, but it brings into question why PKFTs are identified at all given the assessment/ranking of koala habitat: does not appear to relate to the number of PKFT species in vegetation types. does not appear to relate to the amount of PKTFs in vegetation types. In line with SEPP44, potential habitat

Dr Steven Philips commented that PKFTs form the basis of how habitat is ranked. Ranking is not about numbers per se but about relative abundance. The 15% rule has no basis in science and results in the undervaluing of koala habitat throughout the species range Habitat quality is independent of the presence/absence of koalas. A new section , Section 7.3 has been included in the KMP.

20/11/2019 EES Comments received 29/01/2020 Section 7.3 appears to apply a mixture of two habitat classification options that are suggested in the 2008 NSW Koala Recovery Plan for classifying koala habitat. Based on the information provided in the KMP for the dominance of canopy species (where only the dominance of species noted as PKFTs is provided), EES Group cannot assess the classification of koala habitat using a longer list of koala use trees in order to concur with the KMP’s

Response to EES Comments received 29/01/2020 The proposed classification has been retained based on the advice from Dr. Phillips as it is based on the relative proportion or dominance of PKFTs within the vegetation community Nonetheless, Section 7.3 has been updated to specify that all areas are considered to comprise


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is defined as areas where PKFTs constitute at least 15% pf the total number of trees in the upper or lower strata of the tree component does not account for where koalas were recorded during surveys. Koalas were recorded in vegetation types that were then considered to have lower potential carrying capacity than vegetation types where they were not recorded.

koala habitat rankings. EES Group reiterates its recommendation that all vegetation types on enriched soils that contain trees koalas have been demonstrated to use should be considered equally important habitat. EES Comments received 28/02/2020 The list of PKFTs does not include a number of known feed trees (as previously advised) and is therefore not considered comprehensive. This is not reflected in section 7.3 – all rankings have been collectively grouped as ‘Preferred Koala Habitat’. It is noted, however, that the PKFTs and classification

important koala habitat. Section 7.3 has also been updated to further expand how the proposed classification relates to classifications of Koala tree use outlined in the OEH Review document. Response to EES Comments received 28/02/2020 As previoulsy stated, the list of PKFTs is based on a combination of known food tree species (as listed in the Koala recovery plan) recorded within the Intermodal Terminal site, studies


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system remain unchanged.

of the Campbelltown koala population and expert input from Dr. Phillips and is considered to be comprehensive for the Intermodal Terminal Site. Justification for the exclusion of species (as previously advised by EES group) is addressed in prior responses. As the PKFT list has been unchanged the corresponding habitat classification also remains unchanged. However, Section 7.3 has been amended to remove the term ‘Preferred’ and group all rankings as ‘Koala


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Habitat’.

EES (OEH)

14/11/19

The KMP does not include a clear map of koala habitat – either core or potential habitat, or ranked for high/low potential carrying capacity. KMPs should include maps for koala habitat.

Figure 7 has been updated to reflect the koala habitat rankings described in Section 7.3 There is no evidence of Core Koala Habitat on the site. Occupancy / utilisation is a relatively recent event and KMP is evidence of application of the precautionary principle.

20/11/2019 EES Comments received 29/01/2020 It is noted the revised figure 7 and section 7.3 are prepared in accordance with the soon to be replaced SEPP44 tree list plus trees considered by Dr Phillips as important PKFTs using the categories of koala habitat suggested in the 2008 NSW Koala Recovery Plan. EES Group reiterates its recommendation that all vegetation types on enriched soils that contain trees koalas have been demonstrated to use should be considered equally important habitat.

Response to EES Comments received 29/01/2020 The responses to the previous comments re: updates to Section 7.3 apply. Based on this response Figure 7 has been retained. Furthermore new Section 2.5.1 has been added to acknowledge the upcoming replacement of SEP44.

EES (OEH)

14/11/19

The KMP states on numerous occasions that the Intermodal Precinct is likely to support transient koalas moving through the area, dispersing koalas, or koalas with large

Sentence in Section 7. 1 has been amended to address this issue the last paragraph reads, “Much of the more nutrient rich areas of the Cumberland plain

26/11/2019 EES Comments received 29/01/2020 The amended text does not

Response to EES Comments received 29/01/2020 Section 1.3 and Section 5.4.5 have


Stake-holder

Initial Date





home ranges. While this could be the case, habitat in the Intermodal Precinct could potentially support resident koalas over time as the koala population expands to parts of the former range. EESG Group does not agree that habitat in the study area represents ‘low carrying-capacity habitat on nutrient poor soils’.

(including areas within both the Liverpool and Campbelltown LGAs) have been historically cleared for agricultural and residential land uses. Nonetheless, despite no evidence of occupancy or presence of Core Koala Habitat, some areas within the Intermodal Precinct are capable of supporting medium – high koala population densities”.

address the issue raised and makes the KMP more confusing given continued reference to the precinct supporting transient rather than potentially resident koalas (now or in the future).

been updated to mention potential carrying capacity based on information provided within the most recent EES responses. Sections 7.1, 7.2 and 7.3 have also been updated to further clarify that koala habitat quality/ carrying capacity is largely based on relative proportion of PKFTs. Dr. Phillips notes that the habitat must be managed with a view to its maintenance within a larger matrix, which is why the connectivity measures proposed have been suggested.


Stake-holder

Initial Date





EES (OEH)

14/11/19

The KMP states that if a koala observed in the MPW development area does not disperse on its own accord after 24h, it would be captured and released into a PKFT in either the Moorebank (Georges River) or Wattle Grove (Bootland) offset sites at a location shown in Figure 9. These locations are not displayed on Figure 9.

Section 8.3.3 on assisted dispersal of koalas has been amended. The reference to Figure 9 as been removed removed from Section 8.3.3.



EES (OEH)

14/11/19

The monitoring chapter mentions that koalas should be surveyed via spotlighting and Rapid-SAT but no further information is provided for spotlighting surveys. There is also no information on the number of rapid-SAT sites across the offset sites and the size of the monitoring grid. The monitoring chapter states that data from monitoring will contribute to understanding of the process and success of koala relocation, but no further information is provided about this and how success would be measured.

Section 9.1 has been updated and states that, “The finding of the initial targeted assessment will inform the refinement for a final field design for long-term monitoring. The final design is to be consistent with 95% - 99% Rapid-SAT assessment criteria requirements and will be reliant upon a 250 m survey grid. The final design will be submitted for approval prior to commencement of annual monitoring”. Section 9.1.1 has been updated to




Stake-holder

Initial Date





include; “The spotlighting transects will be based within the final RG-bSAT survey grid. Based on the final approved survey grid, spotlighting transects will be placed to enable sufficient replication to effectively survey ~ 25% of retained habitat at each survey event. The monitoring grid will be focussed on the habitat within the offset areas contained within the Intermodal Precinct boundaries only. As parts of the proposed habitat connectivity corridor lie outside of lands owned by the proponent and comprise restricted access lands (i.e. RailCorp land, Holsworthy Military Base), monitoring of koala use of these areas is considered to be outside of the scope of this KMP”.


Stake-holder

Initial Date





EES (OEH)

14/11/19

The monitoring chapter states that the objective of the monitoring program includes determining the effectiveness of proposed mitigation and offset measures, but there is no specific information provided for monitoring whether koalas are using habitat corridors provided from the offset areas to Holsworthy Military Barracks and koala bridge structures across fences.

Section 9.1 has been amended and states that; “Given the absence of Core Koala Habitat, small numbers of koalas based on survey data to date and uncertainly in the future extent of northern dispersal of the Campbelltown koala population, there is potential that use of habitat within offset areas by koalas will not be ongoing. Therefore, the primary intent of the monitoring program will be to inform changes in habitat utilisation by koalas within the Intermodal Precinct over required time period. The objectives of the monitoring program will be to quantify any changes in baseline koala habitat use levels and monitor the effectiveness of the proposed mitigation and offset measures as outlined in Chapter 8”.




Stake-holder

Initial Date





EES (OEH)

14/11/19

The monitoring chapter states that monitoring the effectiveness of plantings in offset sites is required, but there is no requirement included to monitor the survivorship of plantings and any targets that should be met.

This issue is addressed in the BA314 Biobanking Agreement

26/11/2019 EES Comments received 29/01/2020 The issue raised has not been adequately addressed. EES Group recommends the KMP be amended to include the Biobanking Agreement requirements to monitor the survivorship of plantings.

Response to EES Comments received 29/01/2020 Section 9.1.3 of the KMP has been updated to reference the relevant sections of the Biobanking Agreement MAP that require monitoring of plantings


Table 12: Response to Environmental Representative comments

Stakeholder Initial Comment Date

Screenshot of typo and/or other issues Response Initial Response Date


Date Comment Closed

ER 18/10/19 Generally, requires additional work to meet Condition of consent C 1 e.g. review protocol and defined roles and responsibilities table.

Table 8 in Appendix A has been updated to address requirements of condition C1

1/12/2019

ER 18/10/19 Section 1.1 Background “Draft Development Consent Conditions have been provided by the Independent Planning Commission (IPC) for the proposed development of MPW Stage 2, located within Lots 1, 2, 3 (partial) DP 1197707, and Lots 100 and 101 DP 1049508 (Figure 2). The MPW Stage 2 development is expected to involve the removal of approximately 42.89 ha of native vegetation, which also comprises habitat for various native flora and fauna, including threatened species. Draft Consent Condition B152 requires preparation of a Koala Management Plan” Term ‘Draft’ not appropriate in final document. Condition number needs to be changed for final document once consent granted

The term ‘draft’ in relation to the consent conditions has been removed from the document

1/12/2019

ER 18/10/19 Section 1.2 The Project Statement has been deleted 1/12/2019





Date Comment Closed

“The client is seeking SSD Consent under Division 4.1 of Part 4 of the Environmental Planning and Assessment Act 1979 (EP&A Act) for the MPW Stage 2 development (Figure 2).” Statement Not appropriate in final document

from Section 1.2 of the KMP

ER 18/10/19 Section 1.2 The Project Construction works and temporary ancillary facilities, including: installation and use of a concrete batching plant; and Confirm that this is still proposed

Cumberland Ecology has been informed by Tactical that this is still proposed

1/12/2019

ER 18/10/19 Section 1.4.1 Cumberland Ecology “BAM Assessor” Define acronym

Definition for acronym provided in Section1.4 and Glossary

1/12/2019

ER 18/10/19 Section 1.5 Document Structure Note that there are additional requirements under CoC C1

Additional requirements under CoC C1 have been added and are referenced accordingly in text

1/12/2019

ER 18/10/19 Section 2.2.1 Division 4.1 of Part 4 of the EP&A Act To be modified for final document

Legislative description regarding SSD has largely been retained. However, text has been amended to state

1/12/2019





Date Comment Closed

that MPW Stage 2 has been approved as a SSD

ER 18/10/19 Section 2.4 NSW BOP for Major Projects and the BOS “The Biodiversity Offsets Policy for Major Projects has recently been replaced by the Biodiversity Offsets Scheme, which was established by the Biodiversity Conservation Regulation 2017 commencing on 25 August 2017. As the SEARs for the SSD 16-7709 were issued prior to 25 August 2017, the MPW Stage 2 development comprised a ‘pending or interim application’ under the Biodiversity Conservation (Savings and Transitional) Regulation 2017. Therefore, the MPW Stage 2 development continues to be assessed under the planning provisions of the TSC Act, FBA and Biodiversity Offsets Policy for Major Projects, as required by the SEARs.” final document to reflect determination and consent

Section 2.4 has been updated to reflect that the MPW Stage 2 project was approved as a SSD based on assessments using the FBA.

1/12/2019

ER 18/10/19 Section 2.6 Koala Recovery Plan “The koala food trees differ between in the

Sentence amended 1/12/2019





Date Comment Closed

seven management areas”. Check grammar

ER 18/10/19 Section 5.2.5 Survey Limitations Due to time limitations during the survey period, scats found within the Bootland on 7 December 2018 were not included in the samples sent to ScatsAbout for laboratory analysis. Samples sent for identification were limited to the scats collected during the Rapid-SAT surveys on 30 November 2018 and during the detection dog surveys within the MPW site on 5 December 2018. Comment on the impact of this on the reliability of the results

Additional information on reliability of the results provided.

1/12/2019

ER 18/10/19 Section 8.3 Mitigation Measures For clarity and to assist in meeting the requirements of the plan the mitigation measures described within the text below should be distilled into a table of mitigation measures provided in this document of the CFFMP

Table of mitigation measures provided in new Appendix B

1/12/2019

ER 18/10/19 Section 8.3.5.1 Fencing However, it is understood that these areas

Statement removed as it has been confirmed that that

1/12/2019





Date Comment Closed

are to be included as part of the offset area and that BA 341 will be amended accordingly (R. Johnson, pers. comm.) Needs to be a clear mitigation measure

BA341 is no longer proposed to be amended.

ER 18/10/19 Section 8.3.5.4 Limitations to Habitat Corridor Enhancement an alternative strategy for koala management to those proposed within this KMP will be required, a view that is supported by Dr Phillips. this needs to be a clear mitigation measure

An alternative strategy, if required due to consent for land access not being granted by RailCorp and Department of Defence, will require a completely separate Koala Plan of Management to be prepared for management of Koalas on the site in place of the current KMP. As the requirement of this alternate Koala Management Plan is yet to be confirmed, this alternate strategy has not been detailed within this KMP as it requires a completely different scope and objectives. In lieu of preparing an alternate KMP, this potential requirement is limited to an

1/12/2019





Date Comment Closed

acknowledgement within the current KMP that a different Plan of Management may be required if consent is not granted by the relevant landowners

ER 18/10/19 Section 8.4 Direct Offset Therefore, no species credits have been created within the Biobank site for this species. However, based on the presence of Koalas in the Bootland, it is anticipated that species credits for Koala could be generated within the Biobank site. This is proposed to be done as a variation to the biobanking agreement with any deficit of koala credits being purchased as required. There needs to be a commitment made as a mitigation measure

Text has been amended to a commitment to purchase and retire the appropriate number of koala credits

1/12/2019

ER 18/10/19 Section 9.1 Monitoring It is proposed that any Koala population or individual within the Bootland and Moorebank Offset Area will be monitored in conjunction with other fauna monitoring commitments under the FFMP. Monitoring

Table for inclusion in the CEMP an OEMP are provided in Appendix B

1/12/2019





Date Comment Closed

will be Al monitoring requirements outlined here must be tabulated and included in the CFFMP and OEMP

ER 18/10/19 Section 9.1.2 Reporting of Road Kills/Injuries This information will then be used to incorporate appropriate measures into management strategies and other components of the monitoring program as required. Needs to be included as part of a periodic review protocol as per CoC C1

Requirement for periodic review and incidents/non-compliance added as Section 9.4 and Section 9.5 respectively

1/12/2019

ER 18/10/19 Appendix A: Table 13: Independent Planning Commission – Ecological Conditions of Consent IPC Condition consent C1 is also applicable Revise to refer to consent number for final document

Condition C1 added to Table in Appendix A.

1/12/2019

Moorebank Precinct West Stage 2 Final | SIMTA Cumberland Ecology ©

FIGURES

Figure 1. Layout of the Moorebank Intermodal Terminal Precinct

LegendMoorebank Precinct West (MPW) Development Site

Moorebank Precinct East (MPE) Development Site

MPE Stage 1 Construction Area Rail Link

Intermodal Precinct

Wattle Grove Offset Site (Bootland)

Moorebank Offset Site (Georges River)

Casula Offset Site (Hourglass)

0 100 200 300 400 m

Coordinate System: MGA Zone 56 (GDA 94)

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Image © NearMap 2018Dated: 2/11/2018

Geo

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East Hills Railway

M5 Motorway

Figure 2. Location of MPW Stage 2 development




Intermodal Precinct

0 100 200 300 400 m


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Figure 3. Historic Koala records in the locality




Intermodal Precinct

Locality 5 km (MPW)




Koala Records!( 1980 - 1999

!( 2000 - Present

0 400 800 1,200 1,600 m


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Figure 4. Koala Survey Locations

LegendMoorebank Precinct West(MPW) Development Site

Moorebank Precinct East(MPE) Development Site

MPE Stage 1 ConstructionArea Rail Link

Intermodal Precinct

Wattle Grove Offset Site(Bootland)

Moorebank Offset Site(Georges River)

Casula Offset Site(Hourglass)

Koala Detection DogTracks

Monday (3/12)

Tuesday (4/12)

Wednesday (5/12)

Thursday (6/12)

Friday (7/12)

Additional Koala Surveys

!(Rapid-SAT SurveyLocations

!( IR Camera Locations

0 100 200 300 400 m


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Figure 5. Koala Survey Results

LegendMoorebank Precinct West(MPW) Development Site

Moorebank Precinct East(MPE) Development Site

MPE Stage 1 ConstructionArea Rail Link

Intermodal Precinct

Wattle Grove Offset Site(Bootland)

Moorebank Offset Site(Georges River)

Casula Offset Site(Hourglass)

Koala Indicators

!( Koala Detection Dog - Scats

!( Rapid-SATs - Scats

!( IR Camera Recording

0 100 200 300 400 m


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. Koa

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M5 Motorway

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Geo

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Figure 6. Location of Intermodal Precinct relative to Campbelltown LGA




Intermodal Precinct

Local Government Area Boundary




0 350 700 1,050 1,400 m


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IImage Source:


Liverpool LGA

Campbelltown LGA

Geo

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GLENFIELD

CASULA

LONG POINT

MOOREBANKLiverpool LGA

Figure 7. Vegetation communities of the MPW site and offset areas

LegendMooreba nk Precinct We st(MPW) Deve lopm e nt SiteMooreba nk Precinct Ea st(MPE) Deve lopm e nt SiteMPE Sta g e 1 ConstructionAre a Ra il Link

Inte rm od a l Pre cinct

Wa ttle Grove O ffse t Site(Bootla nd )Mooreba nk O ffse t Site(Ge org e s Rive r)Ca sula O ffse t Site(Hourg la ss)

Vegetation CommunityME002 Broa d -le a ve dIronba rk - Me la le uca d e corashrubby ope n fore st on cla ysoils of the Cum be rla ndPla in, Syd ne y Ba sinBiore g ionME003 Ha rd -le a ve dScribbly Gum - Pa rra m a ttaRe d Gum he a thy wood la ndof the Cum be rla nd Pla in,Syd ne y Ba sin Biore g ionME004 Broa d -le a ve dIronba rk – Grey Box –Me la le uca d ecora g ra ssyope n fore st on cla y/g rave lsoils of the Cum be rla ndPla in, Syd ne y Ba sinBiore g ion

ME005 Pa rra m a tta Re dGum wood la nd on m oista lluvium of the Cum be rla ndPla in, Syd ne y Ba sinBiore g ionME007 - Coa sta l fre shwa te rla g oons of the Syd ne yBa sin Biore g ion a nd SouthEa st Corne r Biore g ionME018 Fore st Re d Gum –Roug h-ba rk Apple g ra ssywood la nd on a lluvia l fla ts ofthe Cum be rla nd Pla in,Syd ne y Ba sin Biore g ion

Koala HabitatPrim a ry Koa la Ha bita t:ME018, ME002Second a ry Cla ss A: ME003,ME005

Second a ry Cla ss B: ME004

0 100 200 300 400m

Coord ina te Syste m : MGA Zone 56 (GDA 94)

I:\...\18194\Figures\RP1\20191205\Figure 7. Vegetation communities_MPW and offsets

I

Im a g e Source:Im a g e © Ne a rMa p 2018Da te d : 2/11/2018

M5 Motorwa y

Moorebank Ave nue

Ea st Hills Ra ilway

George s River

Figure 8. Koala Movement Corridors




Intermodal Precinct




0 100 200 300 400 m


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IImage Source:


M5 Motorway

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East Hills Railway

Geo

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Wattle GroveResidential Area

East Hills Railway

Holsworthy MilitaryReserve

Bootland

Holsworthy MilitaryReserve

East Hills Railway

Moorebank OffsetArea

Geo

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Riv

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Inset AInset B

A B

")

")

")

")

")

")

")

")

") ")

") ")

Figure 9. Location of Koala Grids and Bridges

LegendWattle Grove Offset Site(Bootland)Moorebank Offset Site(Georges River)

Proposed FencingExisting Cyclone fence

Existing fence

New Cyclone fence

New fenceNew rural fence (5 strandplain wire)

") Bridge

") Gate/Koala Grid

") Koala Grid

0 100 200 300 400 m


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